quotation marks omitted)); Mund v. English, 69 Ore. App. 289, 684 P.2d 1248, 1249-50 (Or. Ct. App. 1984) (“An irrevocable license does not depend on the proof of the agreement of the parties but arises by operation of law to prevent an injustice.” (collecting cases)); Springob v. Univ. of S.C., 407 S.C. 490, 757 S.E.2d 384, 387-88 (S.C. 2014) (“The doctrine of estoppel may be invoked to prevent a party from asserting the statute of frauds.” (brackets, citation, and internal quo tation marks omitted)); but see One Dupont Centre, LLC v. Dupont Auburn, LLC, 819 N.E.2d 507, 515 (Ind. Ct. App. 2004) (explaining that “if an irrevocable license did existf] ... it would be subject to the statute of frauds” (citation omitted)); Kitchen v. Kitchen, 465 Mich. 654, 641 N.W.2d 245, 249 (Mich. 2002)
holding that estoppel was a question of fact holding that possession of a drivers license is irrelevant to the offense of failing to present a license which is completed by failing to present the license when requested to do so by an officer holding that an irrevocable license by estoppel cannot be created  because it would violate the statute of frauds holding that a statute that created a counselorclient privilege should not be retroactively applied to records created prior to the statute because of the presumption against retroactivity holding that even if district courts failure to give statute of frauds instruction was error it was harmless because appellants failed to demonstrate how the failure to instruct on the statute of frauds affected their substantial rights