Exhibit 5.1








                                  May 24, 1999


PLM International, Inc.
One Market
Steuart Street Tower, Suite 800
San Francisco, California  94105-1301




                           Re:  Registration Statement on Form S-8

Ladies and Gentlemen:

         I am Vice President and General Counsel to PLM  International,  Inc., a
Delaware corporation (the "Company"),  and have acted as such in connection with
the  preparation  of a  Registration  Statement  on Form S-8 (the  "Registration
Statement")  of the Company to be filed by the Company with the  Securities  and
Exchange  Commission (the "Commission")  pursuant to the Securities Act of 1933,
as amended (the "Act").  The Registration  Statement  relates to the issuance by
the  Company of up to 820,000  shares (the  "Shares")  of the  Company's  common
stock,  par value  $0.01  per share  ("Common  Stock"),  issuable  under the PLM
International,  Inc. 1998 Management Stock Compensation Plan, as amended and the
PLM  International,  Inc.  Directors'  1995  Nonqualified  Stock Option Plan, as
amended (such plans, collectively, the "Plans").

         This opinion is delivered in accordance  with the  requirements of Item
601(b)(5) of Regulation S-K promulgated under the Act.

         In connection with this opinion,  I have examined (i) the  Registration
Statement as proposed to be filed with the Commission, (ii) the Plans, (iii) the
Certificate  of  Incorporation  and the By-laws of the Company,  in each case as
amended to the date hereof, (iv) the form of certificate representing the Shares
and (vi) such records of the Company and such agreements, certificates of public
officials,  certificates of officers or other representatives of the Company and
others and such other documents as I have considered necessary or appropriate as
a basis for the opinion set forth below.

         In my  examination,  I have assumed the  genuineness of all signatures,
the legal capacity of all natural  persons,  the  authenticity  of all documents
submitted  to me as  originals,  the  conformity  to original  documents  of all
documents   submitted  to  me  as  certified  or  photostatic   copies  and  the
authenticity  of the  originals  of such  copies.  In making my  examination  of
documents  executed by parties other than the Company,  I have assumed that such
parties  had the  power,  corporate  or other,  to enter  into and  perform  all
obligations  thereunder  and have  also  assumed  the due  authorization  by all
requisite action, corporate or other, and execution and delivery by such parties
of such documents and the validity and binding effect thereof on such parties.

         I am  admitted to the bar of the State of  California  and I express no
opinion as to the laws of any other jurisdiction, except for the federal laws of
the United  States of America  and the General  Corporation  Law of the State of
Delaware to the extent specifically referred to herein.

         Based  upon the  foregoing  and  subject  to the  foregoing  and to the
limitations,  qualifications,  exceptions and assumptions set forth herein,  and
assuming  (i) the valid  issuance  of options  pursuant  to the Plans,  (ii) the
conformity  of the  certificates  representing  the  Shares to the form  thereof
examined  by me and  (iii)  the  due  execution  and  countersignature  of  such
certificates,  I am of the opinion  that the Shares,  when issued in  accordance
with  the  terms  of  the  Plans,  will  be  validly  issued,   fully  paid  and
nonassessable.

         For  purposes  of this  opinion,  I have  assumed  that,  prior  to the
issuance  of any of the  Shares,  (i) the  Registration  Statement,  as  finally
amended (including all necessary post-effective amendments),  becomes effective;
(ii) the  exercise  price of the Shares  issued under the Plans will not be less
than the par value of such Shares at the time of  issuance;  (iii) there will be
no agreements,  indentures, mortgages, deeds of trust or instruments that affect
the  ability  of  the  Company  to  issue  the  Shares;  and  (iv)  certificates
representing the Shares will be manually signed by an authorized  officer of the
transfer  agent for the Common Stock and will be registered by the registrar for
the Common Stock.

         I hereby  consent  to the  filing of this  opinion as an exhibit to the
Registration  Statement. In giving such consent, I do not admit that I come into
the category of persons whose consent is required  under Section 7 of the Act or
the rules and regulations of the Commission promulgated thereunder.

                               Very truly yours,


                               /s/ Susan C. Santo
                               -------------------------------------
                               Susan C. Santo
                               Vice President and General Counsel