See Harold Gill Reuschlein & William A. Gregory, The Law of Agency and Partnership, § 12 (2d ed. 1990) ('Agency is a consensual relationship.'). An agency relationship can arise in different ways: While the creation of an agency relationship, so far as the principal and agent are concerned, arises from their consent and usually as the result of a contract, it is not essential that any actual contract exist or that compensation be expected by the agent or agreed to by the parties. While the relationship, in its full sense, arises out of a contractual or gratuitous agreement between the parties, … the agency and the assent of the parties thereto may be either express or implied. …'An express agency is an actual agency created as a result of the oral or written agreement of the parties, and an implied agency is also an actual agency, the existence of which as a fact is proved by deductions or inferences from the other facts and circumstances of the particular case, including the words and conduct of the parties.' 3 Am. Jur. 2d Agency § 18 (1986).