 Prime ideal avoiding a multiplicative subset

In a Noetherian ring, an ideal $I$ disjoint from a nonempty multiplicative subset $S$ extends to an ideal $P$ maximal among those disjoint from $S$, by the ascending chain condition. It is proper. If $ab\in P$ but neither factor belongs to $P$, both $P+(a)$ and $P+(b)$ meet $S$. Multiplying such representatives puts an element of $S$ in $P$, a contradiction. Thus $P$ is a prime ideal. For a general commutative ring the same argument follows after applying the Zorn lemma to disjoint ideals; the union of a chain is disjoint from $S$.