With mine it is all down to timing and how they are picked up. About 1 hour after eating treats, in the afternoon when they are feeling settled, when they are roosting on their very highest perch and are chest-height to me, some of them will permit me to gently pick them up by scooping up their feet and steadying their backs. Then if I hold my arms very still they will sit down on my arms.
The same chickens, when feeling perky and running around, turn into utter jerks when I try to pet them or pick them up if I am standing and they are on the ground. And they bite hard.