The U.S. Supreme Court has held that when a police officer approaches a subject, identifies himself as a police officer, and politely asks if he/she may speak with the subject, then a reasonable person does not feel restrained or required to communicate with the officer. The key for creating a voluntary contact is to request cooperation in a manner that suggests an option, or the officer may simply initiate a normal, noncoercive conversation. Even when reasonable suspicion to detain or probable cause to arrest exists, the use of a voluntary contact is often preferable because it does not carry the restrictive legal requirements that apply to an investigative stop or an arrest. It is also likely that a voluntary contact will not precipitate defensiveness in the subject, which would impede the free flow of information. A subject who is less defensive is also more likely to consent to a search. A subject's voluntary compliance with an officer's instructions or demands is not the same thing as a voluntary contact. Officers must choose their words and manner of delivery carefully, such that a reasonable person would not believe that he/she is legally required to do what the officer says or risk a legal sanction.