November 5, 2002                                                     Exhibit 5


Case Credit Corporation
233 Lake Avenue
Racine, Wisconsin 53403

CNH Capital Receivables Inc.
100 South Saunders Road
Lake Forest, Illinois 60045

CNH Equipment Trust 2002-B
233 Lake Avenue
Racine, Wisconsin 53403

            Re:   CNH Capital Receivables Inc.
                  Registration Statement on
                  Form S-3 (Registration No. 333-98887)

Ladies and Gentlemen:

     We have acted as special counsel for CNH Capital Receivables Inc., a
Delaware corporation (the "Company"), in connection with (a) the
above-captioned Registration Statement (such registration statement, together
with the exhibits and any amendments thereto, the "Registration Statement"),
filed by the Company with the Securities and Exchange Commission in connection
with the registration by the Company of Asset Backed Notes and Asset Backed
Certificates with a proposed maximum aggregate offering price of
$5,000,000,000 and (b) the contemplated sale under the Registration Statement
on November 19, 2002 of $270,000,000 of Class A-1 Asset Backed Notes (the
"Class A-1 Notes"), $270,000,000 of Class A-2 Asset Backed Notes (the "Class
A-2 Notes"), $305,000,000 of Class A-3 Asset Backed Notes (the "Class A-3
Notes"), $186,250,000 of Class A-4 Asset Backed Notes (the "Class A-4 Notes")
and $35,750,000 of Class B Asset Backed Notes (the "Class B Notes" and,
together with the Class A-1 Notes, the Class A-2 Notes, the Class A-3 Notes
and the Class A-4 Notes, the "Subject Notes") issued by CNH Equipment Trust
2002-B (the "Trust").

     In that connection, we are familiar with the proceedings taken by the
Company in connection with the authorization, issuance and sale of the Subject
Notes and have examined copies of such documents, corporate records and other
instruments as we have deemed necessary or appropriate for the purposes of
this opinion, including the Registration Statement and the documents relating
to the issuance of the Subject Notes. Terms used herein without definition
have the meanings given to such terms in the Registration Statement.




     We are also familiar with the certificates of incorporation of the
Company and the servicer and have examined all statutes, corporate records and
other instruments that we have deemed necessary to examine for the purposes of
this opinion.

     Based on the foregoing, we are of the opinion that:

     (i) the Subject Notes will be duly authorized by all necessary action of
     the Trust and will be legally issued and binding obligations of the Trust
     and entitled to the benefits afforded by the related indenture; and

     (ii) the statements set forth in the Prospectus relating to the Subject
     Notes under the captions "U.S. Federal Income Tax Consequences,"
     "Illinois State Tax Consequences" and "ERISA Considerations" (as modified
     by the statements, if any, set forth under the headings "Summary of
     Terms--Tax Status," "Summary of Terms --ERISA Considerations" and "ERISA
     Considerations" in the related Prospectus Supplement) accurately reflect
     our opinion.

     Our opinions expressed herein are limited to the federal laws of the
United States, the laws of the State of New York, the laws of the State of
Illinois and the business trust laws of the State of Delaware.





                             Very truly yours,



                             /s/ MAYER, BROWN, ROWE & MAW


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