Which of the following is NOT a way agency relationship can be created?

Agency relationships can be established through various means, including express agreements, estoppel, and implication. However, intention alone does not create an agency relationship unless it is manifest in one of these recognized forms.

An express agreement involves a clear, formal contract where both parties agree to the agency terms, detailing responsibilities and authority. Estoppel occurs when one party acts in a way that leads another party to reasonably believe an agency relationship exists, thus creating an agency by implication of understanding. Implication arises from the conduct of the parties or the circumstances surrounding their relationship, allowing for an agency to be inferred even in the absence of a formal agreement.

In contrast, intention by itself does not establish an agency relationship without additional conditions being met. Simply having the intent to create an agency does not suffice; there needs to be a demonstration of that intent through actions or agreements. Therefore, the lack of a necessary formalized agreement or other supporting mechanism makes intention not a standalone basis for creating an agency relationship.