1 Exhibit 5.1 [Vinson & Elkins L.L.P. Letterhead] August 13, 1998 Quaker State Corporation 225 East John Carpenter Freeway Irving, Texas 75062 Re: Registration Statement on Form S-8 for the Non-Employee Directors Restricted Stock Gentlemen: We have acted as counsel to Quaker State Corporation, a Delaware corporation (the "Corporation"), in connection with the above-captioned registration statement (the "Registration Statement") relating to the 65,385 shares (the "Plan Shares") of Capital Stock, par value $1.00 per share, of the Corporation that may be issued under its Non-Employee Director Restricted Share Agreements (the "Plan"). Either authorized but unissued or treasury shares of Capital Stock may be used under the Plan. In rendering our opinion below, we have assumed that only authorized but unissued shares will be issued under the Plan. In connection with this opinion, we have examined, among other things: 1. resolutions adopted by the Corporation's Board of Directors on February 4, 1998; 2. the Certificate of Incorporation of the Corporation as in effect at all times since the last amendment to the Certificate of Incorporation effective June 13, 1997; 3. the Bylaws of the Corporation, as amended and restated effective on May 15, 1998; 4. the Plan, as approved by the Corporation's stockholders at the Corporation's Annual Meeting of Stockholders held on May 15, 1998; 5. a copy of the Report of Inspectors of Election, indicating that the Plan was approved by the Corporation's stockholders at the Corporation's Annual Meeting of Stockholders held on May 15, 1998; and 2 Quaker State Corporation August 13, 1998 Page 2 6. the form of Non-Employee Director Restricted Share Agreement to be executed by the non-employee directors and the Company. As to matters of fact relevant to the opinions expressed herein, and as to factual matters arising in connection with our examination of corporate documents, records and other documents and writings, we have relied upon certificates and other communications of corporate officers of the Corporation, without further investigation as to the facts set forth therein. Based on the foregoing and upon an examination of such other documents, corporate proceedings, statutes, decisions, certificates of public officials, and questions of law as we considered necessary in order to enable us to furnish this opinion, we advise you that in our opinion the Plan Shares have been duly authorized, and upon issuance in accordance with the provisions of the Plan, will be validly issued, fully paid and nonassessable. The opinion expressed above is subject to the following assumptions, exceptions and qualifications: a. We have assumed that (i) all information in all documents reviewed by us is true and correct, (ii) all signatures on all documents reviewed by us are genuine, (iii) all documents submitted to us as originals are true and complete, (iv) all documents submitted to us as copies are true and complete copies of the originals thereof, (v) each person signing any document reviewed by us in any representative capacity had proper authority to do so, and (vi) each natural person signing any document reviewed by us had the legal capacity to do so. b. We are admitted to practice law in the State of Texas. The foregoing opinion is limited to the General Corporation Law of the State of Delaware and the federal laws of the United States of America. We express no opinion as to any matter other than as expressly set forth above, and no opinion on any other matter may be inferred or implied herefrom. We hereby consent to the filing of this opinion as an Exhibit to the Registration Statement and to the use of our name under the caption "Legal Opinion" in the Section 10(a) prospectus and the reoffer prospectus used in connection with the Plan and the Registration Statement. In giving this consent, however, we do not hereby admit that we are within the category of persons whose consent is required under Section 7 of the Securities Act of 1933 and the rules and regulations of the Securities and Exchange Commission promulgated thereunder. Very truly yours, /s/ Vinson & Elkins L.L.P.