September 15, 1998


Creative Host Services, Inc.
6335 Ferris Street, Suite G-H
San Diego, CA 92126

Re:      Registration Statement on Form S-3for
         953,573 Shares of Common Stock
         and 462,500 Warrants

Ladies and Gentlemen:

We have acted as your counsel in the preparation of a Registration  Statement on
Form S-3 (the  "Registration  Statement")  to be filed with the  Securities  and
Exchange  Commission to cover the resale of up to 953,573 shares of common stock
(the "Common  Stock") and 462,500  Warrants (the "Public  Warrants") of Creative
Host Services, Inc., a California corporation (the "Company") by certain Selling
Securityholders as more particulary described in the Registration Statement.

For  purposes of  rendering  this  opinion,  we have made such legal and factual
examinations as we have deemed necessary under the circumstances and, as part of
such examination,  we have examined,  among other things,  originals and copies,
certified or  otherwise,  identified  to our  satisfaction,  of such  documents,
corporate  records  and  other  instruments  as  we  have  deemed  necessary  or
appropriate.  For  the  purposes  of  such  examination,  we  have  assumed  the
genuineness  of all  signatures  on original  documents  and the  conformity  to
original documents of all copies submitted to us.

On the basis of and in reliance upon the foregoing  examination and assumptions,
we are of the opinion that assuming the Registration Statement shall have become
effective  pursuant to the provisions of the Securities Act of 1933, as amended,
the  shares  of Common  Stock  and  Public  Warrants  to be sold by the  Selling
Securityholders,  have been duly  authorized,  validly  issued,  fully  paid and
nonassessable.

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

Very truly yours,



LUCE, FORWARD, HAMILTON & SCRIPPS LLP