EXHIBIT 5.1

                                     [LETTERHEAD]




                             December 19, 1996



AmerUs Life Holdings, Inc.
418 Sixth Avenue
Des Moines, Iowa,  50309-2407

Ladies and Gentlemen:

         Reference is made to the Registration Statement (Registration No.
333-113713) on Form S-1 filed on October 8, 1996, by AmerUs Life Holdings, Inc.,
an Iowa corporation (the "Company") and AmerUs Capital I, a Delaware business
trust (the "Trust") with the Securities and Exchange Commission ("SEC") under
the Securities Act of 1933, as amended (the "Securities Act")(such registration
statement, as amended from time to time, being hereinafter referred to as the
"Registration Statement") relating, in part, to the registration of 
Deferrable Interest Subordinated Debentures (the "Debentures") and a Guarantee
with respect to preferred securities to be issued by an issuer trust to whom the
Debentures will be issued (the "Guarantee").

         I am familiar with the proceedings to date with respect to the
proposed offering and sale of the Debentures and the Guarantee, and have
examined such records, documents and questions of law, and satisfied myself as
to such matters of fact, as I have considered relevant and necessary as a basis
for this opinion.

         Based on the foregoing, I am of the opinion that:

         1.   The Company is duly incorporated and validly existing under the
laws of the State of Iowa.

         2.   The Debentures are to be issued under an Indenture among the
Company and the Trustee thereunder (hereinafter called the "Indenture"), a form
of which is filed as an exhibit to the Registration Statement.  The Indenture
will be a valid instrument legally binding upon the Company and the Debentures
will be duly authorized and issued and will constitute the legal, valid and
binding obligations of the Company subject as to enforcement to bankruptcy,
insolvency, reorganization, moratorium, fraudulent conveyance or other similar
laws now or hereafter in effect relating to creditors' rights generally,when (a)
the Registration Statement, as finally amended, shall have become effective
under the Securities Act; (b) the Company's Board of Directors or a duly
authorized committee thereof shall have duly adopted final resolutions
authorizing the Indenture and the issuance, sale and delivery of the Debentures
as contemplated by the Registration



AmerUs Life Holdings, Inc.
December 19, 1996
Page Two


Statement and the Indenture shall have been duly executed and delivered by the
Company and the Trustee thereunder, acting by their proper officers, and (c) the
Debentures shall have been duly executed by the proper officers of the Company
and authenticated by the Trustee in accordance with the provisions of the
Indenture and duly delivered to the purchasers thereof against payment of the
agreed consideration therefor.

         3.   The Guarantee is to be issued under a Guarantee Agreement between
the Company and the Trustee thereunder (hereinafter called the "Guarantee
Agreement"), a form of which is filed as an exhibit to the Registration
Statement.  The Guarantee Agreement will be a valid instrument legally binding
upon the Company and the Guarantee will be duly authorized and issued and will
constitute the legal, valid and binding obligation of the Company subject as to
enforcement to bankruptcy, insolvency, reorganization, moratorium, fraudulent
conveyance or other similar laws now or hereafter in effect relating to
creditors' rights generally, when (a) the Registration Statement, as finally
amended, shall have become effective under the Securities Act, (b) the Company's
Board of Directors or a duly authorized committee thereof shall have duly
adopted final resolutions authorizing the Guarantee Agreement and the issuance,
sale and delivery of the Guarantee as contemplated by the Registration Statement
and the Guarantee Agreement shall have been duly executed and delivered by the
Company and the Trustee thereunder, acting by their proper officers and duly
delivered.

         I do not find it necessary for the purpose of this opinion to cover,
and accordingly I express no opinion as to, the application of the securities or
blue sky laws of the various states to the sale of the Debentures or the
Guarantee.

         This opinion is limited to the General Corporation Law of the State of
Iowa and the Securities Act.

         I hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement and to all references to this opinion included in or made
a part of the Registration Statement.

                                  Very truly yours,



                                  /s/ James A. Smallenberger