Exhibit 8.1



                               February 25, 1998


Camden Property Trust
3200 Southwest Freeway
Suite 1500
Houston, Texas 77027

Sir/Madam:

     We have acted as counsel to Camden Property Trust ("Camden"), a Texas real
estate investment trust, in connection with the execution and delivery of the
Agreement and Plan of Merger (the "Agreement") dated as of December 16, 1997, as
amended by Amendment No. 1, dated as of February 4, 1998, by and among Camden,
Oasis Residential, Inc. ("Oasis"), a Nevada corporation and Camden Subsidiary
II, Inc. ("Camden Sub"), a Delaware corporation wholly owned by Camden.  This
opinion letter is being furnished to you, pursuant to Section 6.2(e) of the
Agreement, in connection with the Registration on Form S-4, containing the Joint
Proxy Statement/Prospectus of Camden and Oasis, filed with the Securities and
Exchange Commission on February 16, 1998 (file number 333-45817), as amended
through the date hereof (the "Proxy Statement/Prospectus").  Unless otherwise
defined herein or the context hereof otherwise requires, each term used herein
with initial capitalized letters has the meaning given to such term in the
Agreement.

     In connection with the preparation of this opinion, we have examined and
with your consent relied upon (without any independent investigation or review
thereof) the following documents (including all exhibits and schedules thereto):
(1) the Agreement; (2) the Proxy Statement/Prospectus; (3) representations and
certifications made to us by Camden and Camden Sub; (4) representations and
certifications made to us by Oasis; and (5) such other instruments, opinions and
documents related to the formation, organization and operation of Camden, Camden
Sub and Oasis or to the consummation of the Merger and the transactions
contemplated thereby as we have deemed necessary or appropriate.

     In connection with rendering this opinion, we have assumed (and, with your
consent, are relying thereon, without any independent investigation or review
thereof) that:

     1.   All information contained in each of the documents we have examined
and relied upon in connection with the preparation of this opinion is accurate,
all copies are accurate, and all signatures are genuine.  We have also assumed
that there has been (or will be by the Effective Time of the Merger) due
execution and delivery of all documents where due execution and delivery are
prerequisites to the effectiveness thereof.

     2.   The Merger will be effective and will qualify as a statutory merger
under applicable state law.

     3.   Camden Sub is a "qualified REIT subsidiary" as defined in section
856(i) of the Code.

     4.   Since the date of its organization, Oasis has qualified, and through
the Effective Time of the Merger, will continue to qualify as a real estate
investment trust pursuant to Sections 856 through 859 of the Code.

 
     5.   Each entity formed as a partnership or limited liability company under
applicable state law, in which Camden, Oasis or Camden Sub owns a direct or
indirect interest, is, for federal income tax purposes, properly classified as a
partnership; and further, that each such entity has been classified as a
partnership for federal income tax purposes during the entire period of its
existence during which Camden, Oasis or Camden Sub has owned such direct or
indirect interest therein.

     6.   There does not exist any plan or intention on the part of Oasis
shareholders to engage in a sale, exchange, transfer, distribution (including a
distribution by a partnership to its partners or by a corporation to its
shareholders), redemption or reduction in any way of any such Oasis
shareholders' risk of ownership by short sale or otherwise, or other
disposition, directly or indirectly (collectively, a "Sale") with respect to
shares of Camden Common Stock to be received by Oasis shareholders in the Merger
such that the aggregate fair market value, as of the Effective Time of the
Merger, of the shares of Camden Common Stock subject to such Sales would exceed
fifty percent (50%) of the aggregate fair market value of all outstanding shares
of Oasis capital stock immediately prior to the Merger.

     7.   To the extent any expenses relating to the Merger (or the "plan of
reorganization" within the meaning of Treas. Reg. 1.368-1(c) with respect to the
Merger) are funded directly or indirectly by a party other than the party
incurring such expenses, such expenses will be within the guidelines established
in Revenue Ruling 73-54, 1973-1 C.B. 187.

     8.   No outstanding indebtedness of Camden, Camden Sub or Oasis has or will
represent equity for tax purposes; no outstanding equity of Camden, Camden Sub
or Oasis has represented or will represent indebtedness for tax purposes.

     9.   Any representation or statement made "to the best of the knowledge" or
similarly qualified is correct without such qualification.

     10.  An opinion of counsel, substantially identical in form and substance
to this opinion, will be delivered by Latham & Watkins at the time the Merger is
consummated and will not be withdrawn.

     11.  The Merger will be consummated in accordance with the Agreement and as
described in the Proxy Statement/Prospectus (including satisfaction of all
covenants and conditions to the obligations of the parties without amendment or
waiver thereof); each of Camden and Oasis will comply with all reporting
obligations with respect to the Merger required under the Code, and the Treasury
Regulations thereunder; and the Agreement and all other documents and
instruments referred to therein or in the Proxy Statement/Prospectus are valid
and binding in accordance with their terms.

     Based upon and subject to the foregoing, it is our opinion that the Merger
will qualify as a reorganization under the provisions of section 368(a) of the
Code.  In addition to the assumptions set forth above, this opinion is subject
to the exceptions, limitations and qualifications set forth below:

     1.   This opinion represents and is based upon our best judgment regarding
the application of relevant current provisions of the Code and interpretations
of the foregoing as expressed in existing judicial decisions, administrative
regulations and published rulings and procedures.  Our opinion is not binding
upon the Internal Revenue Service or the courts, and the Internal Revenue
Service is not precluded from asserting a contrary position.  Furthermore, no
assurance can be given that future legislative, judicial or administrative
changes, on either a prospective or retroactive 

 
basis, would not adversely affect the accuracy of the opinion expressed herein.
Nevertheless, we undertake no responsibility to advise you of any new
developments in the application or interpretation of the federal income tax
laws.

     2.   This opinion addresses only the specific tax opinions set forth above,
and does not address any other federal, state, local or foreign tax consequences
that may result from the Merger or any other transaction (including any
transaction undertaken in connection with the Merger).  In particular, we
express no opinion regarding, among other things:

          (i)   whether and the extent to which any Oasis shareholder who has
provided or will provide services to Camden will have compensation income under
any provision of the Code and the effects of such compensation income, including
but not limited to the effect upon the basis and holding period of the Camden
Common Stock received by any such Oasis shareholder in the Merger;

          (ii)  the potential application of the "golden parachute" provisions
(sections 280G, 3121(v)(2) and 4999) of the Code, the alternative minimum tax
provisions (sections 55, 56 and 57) of the Code or sections 305, 306, 357, and
708 of the Code, or the Regulations promulgated thereunder;

          (iii) the tax consequences of the Merger to Camden, Camden Sub or
Oasis, including without limitation the recognition of any gain after
application of any provision of the Code, as well as the Treasury Regulations
promulgated thereunder and judicial interpretations thereof;

          (iv)  the basis of any equity interest in Camden acquired by Camden
Sub in the Merger;

          (v)   the tax consequences of the Merger (including the opinion set
forth above) as applied to specific Oasis shareholders and/or holders of options
or warrants for Oasis stock or that may be relevant to particular classes of
Oasis shareholders and/or holders of options or warrants for stock of Oasis,
including but not limited to dealers in securities, corporate shareholders
subject to the alternative minimum tax, foreign persons, and holders of shares
acquired upon exercise of stock options or in other compensatory transactions.

     3.   No opinion is expressed as to any transaction other than the Merger as
described in the Agreement and the Proxy Statement/Prospectus or to any
transaction whatsoever, including the Merger, if all the transactions described
in the Agreement and the Proxy Statement/Prospectus are not consummated in
accordance with the terms of such Agreement and the Proxy Statement/Prospectus
and without waiver or breach of any material provision thereof or if all of the
representations, warranties, statements and assumptions upon which we have
relied are not true and accurate at all relevant times.  In the event any one of
the statements, representations, warranties or assumptions upon which we have
relied to issue this opinion is incorrect, our opinion might be adversely
affected and may not be relied upon.  No ruling has been (or will be) sought
from the Internal Revenue Service by Camden or Oasis as to any of the federal
tax consequences addressed in this opinion.

     4.   This opinion is intended solely for the purposes set forth in Section
6.2(e) of the Agreement; it may not be relied upon for any other purpose or by
any other person or entity, and may not be made available to any other person or
entity without our prior written consent.

     We hereby consent to the filing of this opinion letter as Exhibit 8.1 to
the Proxy Statement/Prospectus and to the reference to this firm under the
captions "Legal Opinions" and "Federal Income Tax Considerations" in the Proxy

 
Statement/Prospectus.  In giving the consent, we do not thereby admit that we
are an "expert" within the meaning of the Securities Act of 1933, as amended.

                         Sincerely yours,



                         Liddell, Sapp, Zivley, Hill & LaBoon, L.L.P.