Exhibit 5.1

                          [McGuireWoods LLP Letterhead]

December 18, 2002


Board of Directors
Apple Hospitality Two, Inc.
10 South Third Street
Richmond, Virginia  23219

Dear Members of the Board of Directors:

         We have acted as counsel to Apple Hospitality Two, Inc. (the
"Company"), a Virginia corporation, in connection with the preparation of a
registration statement on Form S-4 (File No. 333-101194) to which this opinion
is an exhibit (the "Registration Statement"), which is being filed with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the "Act"), for the registration under the Act of 13,146,667 Units (each Unit
consisting of one common share and one Series A preferred share) of the Company.
Terms not otherwise defined herein shall have the meanings assigned to them in
the Registration Statement.

         We have reviewed originals or copies of (i) the articles of
incorporation, bylaws and other corporate documents of the Company, (ii) certain
resolutions of the Board of Directors of the Company, and (iii) the Registration
Statement and the prospectus included therein (the "Prospectus"). In addition,
we have reviewed such other documents and have made such legal and factual
inquiries as we have deemed necessary or advisable for purposes of rendering the
opinions set forth below.

         Based upon and subject to the foregoing we are of the opinion that:

                 1. The Company is duly organized, validly existing and in good
         standing under the laws of the Commonwealth of Virginia; and

                 2. The Units to be registered under the Registration Statement
         have been duly authorized and, when issued as described in the
         Registration Statement, will be validly issued, fully paid and
         nonassessable.

         We hereby consent to the reference to our firm under the captions
"Legal Matters" and "Material United States Federal Income Tax Consequences" in
the Registration Statement and to the filing of this opinion as an exhibit to
the Registration Statement. In giving this consent, we do not admit that we are
in the category of persons whose consent is required by Section 7 of the Act, or
the rules and regulations promulgated thereunder by the Securities and Exchange
Commission.

                                                     Very truly yours,


                                                     /s/ McGuireWoods LLP