OPINION ON APPELLANT’S PETITION FOR DISCRETIONARY REVIEW
WHITE, Judge.
Our prior opinions are withdrawn.
The trial court convicted appellant of the offense of aggravated possession of cocaine with the intent to deliver. See TEX. HEALTH & SAFETY CODE ANN. § 481.102(3)(D), and § 481.112(a) & (c). On original submission, this Court vacated the judgment of the Court of Appeals and remanded the instant cause to the Court of Appeals “to reconsider appellant’s suppression argument by reviewing the totality of the circumstances of appellant’s arrest in light of California v. Hodari, D.”1 Johnson v. State, 825 S.W.2d 126, at 127 (Tex.Cr.App. 1992). On remand, the Court of Appeals complied with the order of this Court. Sitting en banc, the Court of Appeals affirmed appellant’s conviction. Johnson v. State, 864 S.W.2d 708 (Tex.App.—Dallas 1993). This Court granted appellant’s petition for review.
In his only ground for review, appellant asserts:
“The Court of Appeals erred in following the holding in California v. Hodari, D., [499 U.S. 621] 111 S.Ct. 1547 [113 L.Ed.2d 690] (1991) and holding that appellant was not seized within the meaning of Article 1, § 9 of the Texas Constitution either when police officers confronted him in the breezeway of the apartment complex or when police officers pursued appellant.”
We will affirm the decision of the Court of Appeals.
[230]*230I. The decision of the Court of Appeals
Appellant argued before the Court of Appeals that he was “detained” or “stopped” under TEX.CONST. Art. I, § 9, either when the arresting officers initially confronted him in the breezeway or when the officers chased him and made a show of authority by shouting at him to stop. In its opinion,2 the Dallas Court of Appeals explained it understood “a seizure, for purposes of article one, section nine, to occur when the police have intruded on the freedom of a citizen by momentarily detaining the person. The mere approach of police officers that does not interfere with one’s freedom of movement and causes only minimal inconvenience and loss of time is not a seizure.” Johnson v. State, 864 S.W.2d, at 715; and cases cited therein.
In applying this holding to the facts, the Court of Appeals found when,
“the officers walked around the corner into the breezeway, they did nothing that would lead a reasonable innocent person to believe that he was not free to leave. Their mere presence in this case did not constitute a show of authority. The officers’ mere presence in no way intruded on Johnson’s freedom by momentarily detaining him. Thus, Johnson was not seized under the Fourth Amendment or article one, section nine, when the officers made their presence known by walking into the breezeway and within the view of Johnson and the other two men.”
Johnson v. State, 864 S.W.2d, at 716.
The Court of Appeals then faced the issue whether, under Art. I, § 9, appellant was seized when the officers showed their authority by chasing appellant and shouting at him to stop. The Court of Appeals began by analyzing Art. I, § 9, to determine if it provides more protection than the Fourth Amendment on this issue:
“Heitman clearly gives us the authority to grant defendants greater rights under the Texas Constitution than afforded by the Supreme Court’s interpretation of the
United States Constitution. Because we can do so, however, does not mean that we should do so. State precedent existing before the Fourth Amendment was made applicable to the states does not support granting defendants greater rights under article one, section nine than they currently enjoy under the Fourth Amendment.”3 (emphasis supplied in original.)
Johnson v. State, 864 S.W.2d, at 718.
Though yielding to precedent in Heitman, the Court of Appeals held that Art. I, § 9 does not provide more protection for appellant than does the Fourth Amendment. They believed Art. I, § 9, does not show “an intent to provide a defendant greater protec-. tion under the state constitution than that provided under the Fourth Amendment. See TEX.CONST. Art. I, § 9 interp. commentary (Vernon 1984) (“[T]he language of Article I, Section 9 of the Texas Constitution is substantially the same as that used in the. [the Fourth] Amendment.”).” Johnson v. State, 864 S.W.2d, at 719-720; and sources cited therein.
Yet, under Heitman, the Court of Appeals recognized it could look to interpretations of the Fourth Amendment only as advisory in interpreting Art. I, § 9, and not as controlling authority. Where the Supreme Court’s interpretation of the Fourth Amendment conflicts with Texas public policy or our own interpretations of the Texas Constitution, Texas precedent controls so long as it does not call for a restriction of the rights provided for a defendant under the Federal Constitution. The Court of Appeals then sought to “examine the rationale underlying the Supreme Court’s decision in Hodari and determine whether its conclusion is consistent with Texas precedent and sound public policy.” Johnson v. State, 864 S.W.2d, at 720-721.
Applying the definition of “seizure” in Ho-dari D. to the text of Art. I, § 9, the Court of Appeals determined that furthering a public policy of encouraging compliance with a po[231]*231lice officer’s show of authority will not infringe upon a citizen’s right to be free from an unreasonable seizure. The Court of Appeals found that if a fleeing suspect stopped “as a result of the officer’s show of authority or if he is physically forced to stop, then he will be “seized” under article one, section nine. As long as he chooses to ignore the officer’s show of authority, he will not be permitted to claim that the show of authority interfered with his liberty.” Johnson v. State, 864 S.W.2d, at 722.
The Court of Appeals reasoned a suspect will always be able to contest lawfulness of the seizure in court, and the State will always be required to meet the burden of proving beyond a reasonable doubt the police had a reasonable suspicion to investigate.
“Requiring that a suspect yield to a show of authority or be physically stopped by the police before being deemed “seized” under article one, section nine serves the public interest by encouraging compliance with police orders without sacrificing the suspect’s constitutional rights to challenge the lawfulness of those orders and invoke the statutory exclusionary remedy.”
Johnson v. State, 864 S.W.2d, at 728. The Court of Appeals adopted the conclusion reached by the Supreme Court in Hodari D. to determine when a citizen is seized under Art. I, § 9.
The Court of Appeals then applied this ruling to the facts of the instant case. When the officers chased appellant and shouted at him to stop, their actions “constituted a show of authority that would lead a reasonable innocent person to believe that he was not free to leave.” Had appellant complied with this show of authority, the Court of Appeals believed he could claim to have been seized. When appellant continued to flee from the officers, the Court of Appeals found the officers’ actions did not have a coercive effect on appellant. The Court of Appeals held “the officers’ pursuit of Johnson and ordering him to stop did not constitute a seizure of Johnson under article one, section nine.” Johnson v. State, 864 S.W.2d, at 723-724.
Lastly, the Court of Appeals decided that appellant was seized when he complied with the officers’ orders, with their guns drawn, for him to drop his gun and to stop. “Clearly, a reasonable innocent person would not feel free to leave when two police officers with guns drawn order him to stop.... When Johnson complied with the officers’ orders and stopped, the second prong of the test for seizure was met and he was, at that moment, seized under both the Fourth Amendment and article one, section nine.” The Court of Appeals also found appellant was seized when he dropped the gun and, simultaneously, the Crown Royal bag containing the drugs.
The Court of Appeals concluded that when the officers saw appellant in possession of the handgun before he dropped it in response to their orders, “they had probable cause to arrest Johnson for unlawfully carrying a weapon at the time they seized him.” The Court of Appeals held the subsequent search of the Crown Royal bag was a “lawful war-rantless search incident to a lawful arrest.” Johnson v. State, 864 S.W.2d, at 724.
II. The Dispute Before this Court
As noted above, appellant has only asked us to decide if the Court of Appeals erred when it relied on California v. Hodari, D.4 in deciding appellant was not seized under Art. I, § 9 “either when police officers confronted [232]*232him in the breezeway of the apartment complex or when police officers pursued appellant.”
Appellant attacks the opinion of the Court of Appeals as an “inadequately reasoned response to the important issues raised” in his appeal. Appellant alleges the Court of Appeals inadvertently “fused” arrests and investigatory detentions for purposes of constitutional analysis. In this fusion of arrests and investigatory detentions, appellant asserts the Court of Appeals moved police misconduct occurring prior to the time of an actual seizure outside the protection of Art. I, § 9.
In his case, appellant argues the arresting officers lacked an articulate, reasonable suspicion to detain him for purposes of investigation, and lacked the probable cause to arrest him at the point when they confronted him in the breezeway. Appellant implies he was barred from prevailing upon this argument on direct appeal by the Court of Appeals’ ruling that he was not seized until he acquiesced to the arresting officers’ show of authority.
Appellant urges this court to overrule the Court of Appeals. In his brief, he requests this Court not redefine seizure under Texas law in the way he saw the Supreme Court redefine seizure under the Fourth Amendment. Appellant contends this Court should let the law stand as written prior to the Supreme Court’s decision in Hodari, D.: that a defendant has been seized before he or she is physically restrained if a reasonable person in their position would believe they were not free to leave. To appellant, this is a critical distinction because he argues that a reasonable person would not believe he was free to leave at the time appellant was confronted by the police officers in the breezeway of the apartment complex or when they pursued him.
III. The definition of “seizure” under Art. I, § 9.
In the instant case, this Court must resolve whether Art. I, § 9 requires us to find that a seizure has taken place at the time a reasonable person facing a show of authority believes he or she is not free to leave (the pre-Hodari, D. definition of seizure) or, instead, at the time the suspect has actually yielded to the show of authority or been physically forced to yield (the Hodari, D. interpretation of the Fourth Amendment). In doing so, this Court will have decided whether seizure is to be defined as it was under both the Fourth Amendment and Art. I, § 9 prior to Hodari, D., thereby maintaining for the people of Texas a broader definition of seizure under Art. I, § 9, or will seizure be defined under Art. I, § 9 as the Supreme Court in Hodari, D. defined it under the Fourth Amendment. Today, we choose the latter interpretation of Art. I, § 9.
A.
A plain reading and comparison of the language of the Fourth Amendment and Art. I, § 9 reveals no substantive difference. The Fourth Amendment protects the,
“right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.”
Art. I, § 9 also protects a citizen’s rights to be,
“secure in the persons, houses, papers and possessions, from all unreasonable seizures or searches ...”
A literal interpretation of the text of the Fourth Amendment and Art. I, § 9 reveals their fair and objective meaning. The Fourth Amendment and Art. I, § 9 both protect the same right (freedom from unreasonable searches and seizures) to the same degree (persons, houses, papers, and effects/possessions).5 However, this Court decided in Heitman that decisions of the Supreme Court interpreting the Fourth Amendment are not binding upon Texas courts in their interpretations of Art. I, § 9. Heitman v. State, 815 S.W.2d, at 690. Consequently, in the instant case the Court of Appeals and this Court have undertaken the task of defining “seizure” under Art. I, § 9.
[233]*233In the instant dispute, a distinction between the definitions of seizure under the Fourth Amendment and Art. I, § 9 would not be the product of a literal interpretation and comparison of the language in the two provisions. A valid distinction between Art. I, § 9 and the Fourth Amendment could result only from a combination of the historical constitutional analysis of Art. I, § 9 and a decision that Texas public policy is better served by diverging from the path chosen by the Supreme Court in Hodari, D.
We are not bound to apply the Court’s holding in Hodari, D. to our interpretation of Art. I, § 9, as this Court is not bound by Supreme Court interpretations of the United States Constitution when interpreting provisions of the Texas Constitution. Heitman, 815 S.W.2d, at 690. Nor are we obliged to.be different.- “Because we can [grant defendants greater rights under the Texas Constitution than afforded under the United States Constitution] however, does not mean that we should do so.” (emphasis in original) Johnson v. State, 864 S.W.2d, at 718.
•Texas precedent existing before the Fourth Amendment was made applicable to state actions did not support granting to defendants greater protections from state actions under Art. I, § 9 than they enjoyed from federal actions under the Fourth Amendment. Johnson, Id., and cases cited therein. See, also, Brown v. State, 657 S.W.2d 797, at 799—807 (Tex.Cr.App.1983) (Clinton, J., concurring). After the Fourth Amendment was made applicable to the States in Wolf v. Colorado, 338 U.S. 25, 69 S.Ct. 1359, 93 L.Ed. 1782 (1949), and until Heitman was handed down, this Court interpreted the virtually identical language of Art. I, § 9 and the Fourth Amendment to have the same meaning. Eisenhauer v. State, 754 5.W.2d 159 (Tex.Cr.App.1988).
This Court has compared the language of Art. I, § 9 and the Fourth Amendment in an attempt to discern the reason for the similarities in the two provisions. In Eisenhauer, this Court found any similarity between the two appears to be merely a coincidence of historical fact. Eisenhauer v. State, 754 S.W.2d, at 170. In Autran v. State, 887 S.W.2d 31 (Tex.Cr.App.1994), the plurality believed there had to be an underlying intent for the two provisions to be different because a narrow construction would leave Art. I, § 9, specifically, and the Texas Constitution, generally, void of independent meaning.6 Autran v. State, 887 S.W.2d, at 38.
It would be practically impossible to discern from the language, alone, of Art. I, § 9 the intent of the citizens who framed that provision. There is little if any evidence of the intent of the Framers of Art. I, § 9. Autran v. State, 887 S.W.2d, at 38. We are left with the impression that the language of Art. I,- § 9 is virtually identical to the language of the Fourth Amendment.
The historical context in which Art. I, §. 9 was drafted and adopted might be of some benefit to a determination of whether a “seizure” in Art. I, § 9 bears a meaning that is distinct in its origin from “seizure” in the Fourth Amendment. Art. I, § 9 was drafted at a time when the Bill of Rights did not protect individual citizens from state actions, including actions which infringed upon their right to be free from unreasonable searches and seizures. Barron v. Mayor of Baltimore, 32 U.S. (7 Pet.) 243, 8 L.Ed. 672 (1833). This right could only be protected from the arbitrary acts of the state and its agents by a state constitution. Newman, The “Old Federalism”; Protection of Individual Rights by State Constitution in an Era of Federal Court Passivity, 15 Conn. L.Rev. 21, 21 (1983). At that time, the framers of the Texas Constitution chosé language for Art. I, § 9 that was almost identical to the Fourth Amendment.
It is not unreasonable to conclude from these facts that the framers of the Texas Constitution chose to draft Art. I, § 9 to [234]*234protect Texas citizens from unreasonable searches and seizures by the state in the same way they were protected from unreasonable searches and seizures by the federal government. If they had intended to grant to citizens greater protection from state actions than they enjoyed from federal actions, then they could have drafted Art. I, § 9 at that time to reflect that intent.
This does not mean that this Court’s decision in Heitman is to be reversed, or that there will be a reversion to interpreting Art. I, § 9 in lock-step with the Supreme Court’s interpretation of the Fourth Amendment. Because of the similarity of the two provisions, the Fourth Amendment decisions of the Supreme Court should be viewed, at most, as providing guidance in interpretations of Art. I, § 9. However, if the Courts of Appeals and this Court decide to raise the ceiling of the freedom of Texas citizens from unreasonable searches and seizures, it will be done by choosing in individual cases to interpret Art. I, § 9 in a manner justified by the facts of the case, state precedent on the issue, and state policy considerations.
B.
Until the time of the decisions in Heitman and, then, Hodari, D., this Court interpreted the issue of when a seizure has occurred in the same way as the Supreme Court: a person has been seized when a reasonable person in his position would believe he is not free to leave. Eisenhauer v. State, 754 S.W.2d 159, at 164 (Tex.Cr.App.1988); and United States v. Mendenhall, 446 U.S. 544, at 554, 100 S.Ct. 1870, at 1877, 64 L.Ed.2d 497 (1980).
In Hodari, D., the Court added the requirement that a person has not been seized until he has yielded to a law enforcement officer’s show of authority or when officers physically limit his movement. See Hodari, D., 499 U.S., at 626-628, 111 S.Ct., at 1551. The Court explained in Hodari, D. that a seizure, pursuant to the Fourth Amendment, entails the use of physical force or submission to authority.
“The word “seizure” readily bears the meaning of a laying on of hands or application of physical force to restrain movement, even when it is ultimately unsuccess-ful_ It does not remotely apply, however, to the prospect of a policeman yelling, “Stop, in the name of the law.” at a fleeing form that continues to flee. That is no seizure.”
Hodari, D., 499 U.S., at 626, 111 S.Ct., at 1550.
In Hodari, D., as in the instant case, the defendant urged the Supreme Court to rule that he was arrested when confronted by a show of authority by the police. But the Court declined, ruling an arrest requires either the use of physical force against a suspect or, where that is absent, submission to the assertion of authority by the suspect.
“We do not think it desirable, even as a policy matter, to stretch the Fourth Amendment beyond its words and beyond the meaning of arrest.”
Hodari, D., 499 U.S., at 627, 111 S.Ct., at 1551. A show of authority, without an application of physical force, to which a suspect does not yield is not a seizure under the Fourth Amendment.
As the Supreme Court did in the context of the Fourth Amendment in Hodari D., this Court is left with the task of ruling what a reasonable definition of “seizure” would be in the context of Art. I, § 9. In this case, we find the appellate court’s analysis of the Fourth Amendment to be persuasive when applied to Art. I, § 9. There is nothing in the language of Art. I, § 9 to indicate that the Texas Constitution would provide for a definition of seizure that did not include a requirement either that a suspect submit to a demonstration of authority, or that he be subjected to the use of physical force, in order to be considered to have been seized.
Appellant proposes in the instant ease that he was seized when he was confronted by the police in the breezeway, even though he bolted and ran away at the first sight of the officers, giving no indication of any intention to yield to them. It would be ludicrous to hold that these facts prove appellant was seized before he actually yielded to the orders of the arresting officers and stopped running away from them.
[235]*235To the extent that this ruling deviates from state precedent, we hold it is justified because it serves the public policy of encouraging compliance with police orders. The state legislature has fostered the policy of encouraging suspects to yield to a police show of authority. See TEX.CODE CRIM. PROC.ANN. Art. 38.04(a), and (b). The analysis by the Court of Appeals is persuasive on this issue. See Johnson v. State, 864 S.W.2d, at 722-723.
We hold appellant was not seized for purposes of Art. I, § 9, until he yielded to a show of authority by law enforcement officers. If appellant had not yielded to the officers’ orders, he would not have been seized until he had been physically stopped or restrained by the officers.
C.
Appellant also complains the Court of Appeals fused arrests and investigative detentions in its analysis. First, they did not “fuse”, or otherwise blur the distinctions between, the two. For purposes of constitutional analysis, both investigative detentions and arrests are seizures. They are either reasonable because a trial or reviewing court finds they are based on a constitutionally adequate reasonable suspicion or on constitutionally adequate probable cause, respectively, or they are unreasonable. They both represent a seizure of a citizen by law enforcement officers. The differences between the two are based on the degree of intrusion involved in both seizures, and the different legal justifications required of each.
When reviewing an investigative detention under either state or federal law, it is accepted that “law enforcement officers may stop and briefly detain persons suspected of criminal activity on less information than is constitutionally required for probable cause to arrest.” Crockett v. State, 803 S.W.2d 308, at 311 (Tex.Cr.App.1991); and cases cited therein. “Nevertheless, even a temporary detention of this kind is not permissible unless the circumstances upon which the officers rely objectively support a reasonable suspicion that the person detained actually is, has been, or soon will be engaged in criminal activity.” Id., and cases cited therein. See, also, Montano v. State, 843 S.W.2d 579, at 581-582.(Tex.Cr.App.1992). An investigative detention is a confrontation of a citizen by law enforcement officers wherein the citizen yields to a display of authority and is temporarily detained for purposes of an investigation. This is a seizure of the citizen which is reviewed under Fourth Amendment and Art. I, § 9 principles to determine if the detaining law enforcement officer’s suspicions of the citizen are reasonable.
In comparison, when analyzing an arrest under the Fourth Amendment or Art. I, § 9, the reviewing court must determine if the law enforcement officer had probable cause to arrest a citizen. Because an arrest is a more restrictive detention than an investigative detention, the State must satisfy a greater burden of proof and establish that the officer had probable cause to arrest.
Both an investigative detention and an arrest, as seizures, can be contrasted with a confrontation between a citizen and a law enforcement officer that is not a seizure. A law enforcement officer is permitted to approach a citizen without reasonable suspicion or probable cause in order to ask questions and even to request a consent to search. Florida v. Royer, 460 U.S. 491, at 497-498, 103 S.Ct. 1319, 1323-1324, 75 L.Ed.2d 229 (1983). In this example, the citizen is free to ignore the officer and walk away. Id. While a law enforcement officer is free to approach a citizen and ask questions, the citizen is also free to not answer the questions. These encounters are consensual so long as a reasonable person would feel free “to disregard the police and go about his business.” Hodari, D., 499 U.S., at 628, 111 S.Ct., at 1552. In this situation, the State is not required to prove the law enforcement officer had either a reasonable suspicion or probable cause to approach the citizen and ask questions. It was not a seizure: neither an investigative detention nor an arrest.
Arrests and investigative detentions are distinguishable by the nature of the detentions involved and the constitutional parameters which are applied to determine their legality. See Amores v. State, 816 S.W.2d 407, at 411 (Tex.Cr.App.1991). Pursuant to [236]*236our decision today, under the Fourth Amendment and Art. I, § 9, in either an investigative detention or an arrest, the seizure of the citizen has not occurred until a reasonable person would believe he or she was not free to leave, and that person has yielded to the officer’s show of authority or been physically forced to yield.
Second, this decision and the decision of the Court of Appeals did not impair appellant’s ability to claim constitutional protection under Art. I, § 9 by its decision that he was not seized until he yielded to the show of authority. Nothing in either decision will abridge or hinder a defendant’s right to contest the constitutionality of a seizure, whether it is an investigative detention or an arrest. He could still claim the officers lacked a reasonable suspicion to detain him for purposes of investigation, or probable cause to arrest him. The State would still need to have proven that before appellant was seized the arresting officers had a reasonable and articulate suspicion to investigate, and probable cause to arrest. The fact that appellant can not claim he was seized until he stopped running and threw down his gun and bag does not excuse any conduct by the arresting officers, or remove appellant from the protection of Art. I, § 9. Appellant’s ground for review is overruled. The judgment of the Court of Appeals is affirmed.
OVERSTREET, MALONEY, and MEYERS, JJ., concur in the result.