Exhibit 5.1


               OPINION OF LOCKE LIDDELL & SAPP LLP




                                        May 11, 2000


Comstock Resources, Inc.
5300 Town & Country Boulevard
Suite 500
Frisco, Texas 75304

Re: Registration Statement on Form S-8

Ladies & Gentlemen:

     We have acted as counsel for  Comstock  Resources,  Inc.,  a
Nevada  corporation  (the  "Company"),  in  connection  with  the
registration  under the  Securities  Act of 1933, as amended (the
"Act"),  of an  aggregate of  2,500,000  shares of the  Company's
common  stock,  $.50 par value per share (the  "Securities").  We
have  examined  such  documents  and  questions of law as we have
deemed necessary to render the opinion expressed below.

     Based upon the  foregoing,  we are of the  opinion  that the
Securities,   when   issued   and  sold  as   described   in  the
above-referenced  Registration Statement, will be legally issued,
fully paid and nonassessable.

     We consent  to the  filing of this  opinion as an exhibit to
the  Registration  Statement  and to the reference to our firm in
the prospectus  under the caption "Legal Matters." In giving this
consent, we do not thereby admit that we come within the category
of persons whose  consent is required  under Section 7 of the Act
or the rules  and  regulations  of the  Securities  and  Exchange
Commission promulgated thereunder.

                                 Sincerely,

                                 LOCKE LIDDEL & SAPP LLP




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