Many commutative algebra textbooks establish that every ideal of a ring is contained in a maximal ideal by appealing to Zorn's lemma, which I dislike on grounds of non-constructivity. For Noetherian rings I'm told one can replace Zorn's lemma with countable choice, which is nice, but still not nice enough - I'd like to do without choice entirely.

So under what additional hypotheses on a ring $R$ can we exhibit one of its maximal ideals while staying in ZF? (I'd appreciate both hypotheses on the structure of $R$ and hypotheses on what we're given in addition to $R$ itself, e.g. if $R$ is a finitely generated algebra over a field, an explicit choice of generators.)

Edit: I guess it's also relevant to ask whether there are decidability issues here.