November 9, 2000

IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY 12203

RE:      IDS Life of New York Account 8, Form S-6
         Pre-Effective Amendment No. 1
         File No. 333-44644

Ladies and Gentlemen:

I am  familiar  with the  establishment  of the IDS Life of New York  Account  8
("Account"),  which is a separate  account of IDS Life Insurance  Company of New
York  ("Company")  established by the Company's Board of Directors  according to
applicable   insurance  law.  I  also  am  familiar  with  the  above-referenced
Registration  Statement  filed by the Company on behalf of the Account  with the
Securities and Exchange Commission.

I have made such examination of law and examined such documents and records as
in my judgement are necessary and appropriate to enable me to give the following
opinion:

1.       The Company is duly incorporated, validly existing and in good standing
         under applicable state law and is duly licensed or qualified to do
         business in each jurisdiction where it transacts business. The Company
         has all corporate powers required to carry on its business and to issue
         the contracts.

2.       The Account is a validly created and existing separate account of the
         Company and is duly authorized to issue the securities registered.

3.       The contracts issued by the Company, when offered and sold in
         accordance with the prospectus contained in the Registration Statement
         and in compliance with applicable law, will be legally issued and
         represent binding obligations of the Company in accordance with their
         terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,


/s/ Mary Ellyn Minenko
    Mary Ellyn Minenko
    Group Counsel