EXHIBIT 8

             [SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP LETTERHEAD]


                                                                January 16, 1997

First Chicago NBD Corporation
One First National Plaza
Chicago, Illinois  60670

First Chicago NBD Capital I
c/o First Chicago NBD Corporation
One First National Plaza
Chicago, Illinois  60670

               Re:  Registration Statement on Form S-3 
                    (Registration No. 333-15649)
                    ----------------------------------


Ladies and gentlemen:

          We have acted as counsel for First Chicago NBD Corporation, a Delaware
corporation (the "Company"), and First Chicago NBD Capital I, a statutory
business trust formed under the laws of the State of Delaware (the "Trust"), in
connection with the above-captioned registration statement on Form S-3 (the
"Registration Statement") filed with the Securities and Exchange Commission
(the "Commission") for the purpose of registering (i) preferred securities
representing undivided beneficial interests in the assets of the Trust (the
"Preferred Securities") and (ii) Junior Subordinated Deferrable Interest
Debentures issued by the Company to the Trust, in connection with the sale of
the Preferred Securities.

          We hereby confirm that, although the discussion set forth under the
heading "UNITED STATES FEDERAL INCOME TAXATION" in the form of Prospectus
Supplement for an offering of Preferred Securities filed as an exhibit to the
Registration Statement (the "Form of Prospectus Supplement") does not purport to
discuss all possible United States federal income tax consequences of the


 
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January 16, 1997
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purchase, ownership and disposition of Preferred Securities, in our opinion,
such discussion constitutes, in all material respects, a fair and accurate
summary of the United States federal income tax consequences of the purchase,
ownership and disposition of Preferred Securities, based upon current law.  It
is possible that contrary positions may be taken by the Internal Revenue
Service and that a court may agree with such contrary positions.


 
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January 16, 1997
Page 3


          This opinion is furnished to you solely for your benefit in connection
with the filing of the Registration Statement and, except as set forth below,
is not to be used, circulated, quoted or otherwise referred to for any other
purpose or relied upon by any other person for any purpose without our prior
written consent.  We hereby consent to the use of our name under the heading
"Legal Matters" in the Form of Prospectus Supplement and the filing of this
opinion with the Commission as Exhibit 8 to the Registration Statement.  In
giving this consent, we do not thereby admit that we are within the category of
persons whose consent is required under Section 7 of the Securities Act of 1933,
as amended, or the rules and regulations of the Commission promulgated
thereunder.  This opinion is expressed as of the date hereof unless otherwise
expressly stated and applies only to the disclosure under the heading "UNITED
STATES FEDERAL INCOME TAXATION" set forth in the Form of Prospectus Supplement
filed as of the date hereof and it assumes that any instrument that is issued
thereunder will have terms identical to those set forth in such Form of 
Prospectus Supplement. We disclaim any undertaking to advise you of any
subsequent changes of the facts stated or assumed herein or any subsequent
changes in applicable law.


                         Very truly yours,


                 _____________________________________________
                  /s/ SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP