Gifford v. Helms was a United States Supreme Court case that addressed the issue of whether a state court could enforce a contract that was made in violation of a state statute. The case involved a contract between two parties, Gifford and Helms, in which Gifford agreed to pay Helms a certain amount of money for the sale of a piece of property. The contract was made in violation of a state statute that prohibited the sale of property without a license. The Supreme Court held that the state court could not enforce the contract because it was made in violation of the state statute. The Court reasoned that the state statute was a valid exercise of the state's police power and that the state had the right to protect its citizens from contracts that were made in violation of the law. The Court also noted that the state had a legitimate interest in protecting its citizens from contracts that were made in violation of the law. The Court's decision in Gifford v. Helms established that a state court could not enforce a contract that was made in violation of a state statute. This decision has been cited in numerous cases since then and has been used to support the idea that a state court cannot enforce a contract that is made in violation of the law.

In Gifford v. Helms, the Supreme Court was asked to decide whether a contract between two parties that provided for an exchange of land in consideration of money and services rendered could be enforced by one party against the other when it had not been recorded as required by state law. The majority opinion held that since the contract had not been properly recorded, it was unenforceable under state law and therefore could not be enforced in court. Justice Field dissented from this decision on the grounds that while recording may have been necessary to give notice to third parties, there was no evidence presented at trial indicating any prejudice suffered by either party due to lack of recordation; thus he argued that enforcing such contracts would promote justice rather than hinder it. He further noted that if states were allowed to invalidate contracts simply because they were not recorded then individuals would suffer great injustice without being able to seek relief through courts or otherwise protect their rights.