Let K be a field and let σ be an automorphism and let δ be a σ-derivation of K. Then we show that the multiplicative group of nonzero elements of the division ring D = K(x; σ, δ) contains a free non-cyclic subgroup unless D is commutative, answering a special case of a conjecture of Lichtman. As an application, we show that division algebras formed by taking the Goldie ring of quotients of group algebras of torsion-free non-abelian solvable-by-finite groups always contain free non-cyclic subgroups.