1 EXHIBIT 5.1 [LETTERHEAD OF MEADOWS, OWENS, COLLIER, REED, COUSINS & BLAU, L.L.P.] September 30, 1998 Silverleaf Resorts, Inc. 1221 Riverbend Drive Suite 120 Dallas, Texas 75247 RE: SILVERLEAF RESORTS, INC. -- COMMON STOCK, PAR VALUE $0.01 PER SHARE Ladies/Gentlemen: At your request, we have examined the Registration Statement on Form S-8 (the "Registration Statement"), which you intend to file with the Securities and Exchange Commission in connection with the registration under the Securities Act of 1933, as amended, of 1,600,000 shares of Common Stock, par value $0.01 per share (the "Shares"), to be sold by Silverleaf Resorts, Inc. (the "Company") under The 1997 Stock Option Plan, as amended, of Silverleaf Resorts, Inc. (the "Plan"). We are familiar with the proceedings undertaken in connection with the authorization, issuance and sale of the Shares. Additionally, we have examined such questions of law and fact as we have considered necessary or appropriate for purposes of this opinion. Based upon the foregoing, we are of the opinion that the Shares have been duly authorized, and upon issuance of the Shares under the terms of the Plans and delivery and payment therefor of the consideration set forth in the Texas Business Corporation Act at least equal to the aggregate par value of the Shares issued, such Shares will be validly issued, fully paid and nonassessable. We consent to your filing this opinion as an Exhibit to the Registration Statement. Very truly yours, MEADOWS, OWENS, COLLIER, REED, COUSINS & BLAU, L.L.P.