Exhibit 5.1
Opinion of Counsel

    
                               January 29, 1999      

The Board of Directors
Rich Coast Inc.
10200 Ford Road
Dearborn,  MI  48126

RE:  FORM S-3 REGISTRATION STATEMENT
     OPINION OF COUNSEL

Dear Sirs:

     As securities counsel for Rich Coast Inc. (the "Company") a Nevada
corporation, we have examined the originals or copies, certified or otherwise
identified, of the Articles of Incorporation and Bylaws of the Company,
corporate records of the Company, including minute books of the Company as
furnished to us by the Company, certificates of public officials and of
representatives of the Company, statutes and other records, instruments and
documents pertaining to the Company as a basis for the opinions hereinafter
expressed.  In giving such opinions, we have relied upon certificates of
officers of the Company with respect to the accuracy of the factual matters
contained in such certificates.
    
     We have also, as such counsel, examined the Registration Statement on Form
S-3/A No.1, File No. 333-63289 (the "Registration Statement") to be filed with
the Commission on or about February 2, 1999 covering the resale of up to
3,561,457 shares of Common Stock of the Company by the Selling Shareholders, as
more particularly described in the Registration Statement.     

     Based upon the foregoing and subject to the other qualifications and
limitations stated in this letter, we are of the opinion that the shares of
Common Stock to be issued to holders of the warrants or debentures held by the
Selling Shareholders, upon exercise and payment of the exercise price stated in
the warrants, or upon conversion of the debentures, will have been duly
authorized, validly issued, fully paid and non-assessable.
    
     This opinion is a legal opinion and not an opinion as to matters of fact.
This opinion is limited to the laws of the State of Nevada and the federal law
of the United States of America, and to the matters stated herein.  This opinion
is made as of the date hereof, and after the date hereof, we undertake no, and
disclaim any, obligation to advise you of any change in any matters set forth
herein.  This opinion is furnished to you solely in connection with the
transactions referred to herein, and may not be relied on by any other person,
firm or entity without our prior written consent.     

     We acknowledge that we are referred to under the caption "Legal Matters"
included in the Registration Statement.  We hereby consent to such use of our
name in the Registration Statement and to the filing of this opinion as an
Exhibit thereto.  In giving this consent, we do not thereby admit that we come
within the category of persons whose consent is required under Section 7 of the

     
The Board of Directors
Rich Coast Inc.
January 29, 1999      
Page 2

United States Securities Act of 1933 or the Rules and Regulations of the
Securities and Exchange Commission promulgated thereunder.

                                    Very truly yours,

                                    /s/ Smith McCullough, P.C.