Select Objects Behind with Cmd/Ctrl click only works on filled objects
https://helpx.adobe.com/illustrator/using/selecting-objects.html#select_behind_objects
The option to select objects behind by holding Cmd/Ctrl and clicking sequentially works when clicking an object's fill, but not its path. As such, it doesn't work if 'Object Selection by Path Only' is enabled in preferences.
I can't think of a reason it shouldn't work when clicking on a path, so I'm reporting as a bug.
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A related request:
Add the ability to select an object by clicking it's visual appearance (strokes, glyphs, effects)
http://illustrator.uservoice.com/forums/333657/suggestions/32403916 -
Meghann Halfmoon commented
I've contacted Adobe about this in the past. It is still not working. I have selected "Control Click to Select Objects Behind" in Preferences...and yet this does not work. Please get it to work. It's a pretty important function.