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                                                                    EXHIBIT 8.1



                     [LOCKE LIDDELL & SAPP LLP LETTERHEAD]


                                August 24, 1999


Camden Property Trust
Three Greenway Plaza
Suite 1300
Houston, Texas 77046

Ladies and Gentlemen:

         We have acted as securities counsel to Camden Property Trust, a Texas
real estate investment trust (the "Company"), in connection with the
registration by the Company under the Securities Act of 1933, as amended (the
"Securities Act"), of 672,490 common shares of beneficial interest of the
Company, par value $0.01 per share (the "Camden Common Shares"), on a
Registration Statement on Form S-3 (the "Registration Statement") filed with
the Securities and Exchange Commission (the "Commission"). The Camden Common
Shares are to be issued to certain holders of units of limited liability
company interest (the "Units") of Oasis Martinique, LLC, a Delaware limited
liability company ("Oasis Martinique"), upon exchange of the Units.

         The opinions set forth in this letter are based on relevant provisions
of the Internal Revenue Code of 1986, as amended (the "Code"), Treasury
Regulations promulgated thereunder (including proposed and temporary
Regulations), and interpretations of the foregoing as expressed in court
decisions, administrative determinations, the legislative history and existing
administrative rulings and practices of the Internal Revenue Service ("IRS")
(including its practices and policies in issuing private letter rulings, which
are not binding on the IRS except with respect to a taxpayer that receives such
a ruling), all as of the date hereof. These provisions and interpretations are
subject to change, which may or may not be retroactive in effect, that might
result in modifications of our opinion.


         In rendering the following opinion, we have examined such statutes,
regulations, records, certificates and other documents as we have considered
necessary or appropriate as a basis for such opinion, including the following:
(1) the Registration Statement (including all amendments made thereto through
the date hereof); (2) the Amended and Restated Declaration of Trust and the
Second Amended and Restated Bylaws of the Company, as amended to date; (3) the
Registration Rights Agreement, dated as of April 6, 1986, by and among Oasis
Residential, Inc., ISCO and IFT Properties, Ltd.; (4) the Registration Rights
Agreement, dated as of April 2, 1998, by and between Oasis Residential, Inc.
and Merrill Lynch International Private Finance Limited; (5) the Amended and
Restated Limited Liability Company Agreement of Oasis Martinique, LLC, dated as
of October 23, 1998, by and among Oasis Residential, Inc. and the persons named
therein; (6) the Exchange Agreement, dated as of October 23, 1998, by and among
Oasis Residential, Inc., Oasis Martinique, LLC and the holders listed thereon;
and (7) certain written factual representations of the Company contained in an
Officer's Certificate to Counsel for Camden Property Trust regarding certain
income tax matters dated on or about the date hereof (the "Officer's
Certificate").


         In our examination, we have assumed (without any independent
investigation or review thereof), with your consent, that all of the factual
representations and factual statements set forth in the documents we reviewed
are true and correct, and all of the obligations imposed under such documents
have been and will be performed or satisfied in accordance with their terms. We
have further assumed the genuineness of all signatures, the legal capacity of
natural persons, the authenticity of all documents submitted to us as
originals, the conformity to original documents of all documents submitted to
us as certified or photostatic copies, the authenticity of the originals of
such copies and the


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authenticity of telegraphic or telephonic confirmations of public officials and
others. As to facts material to our opinion, we have relied upon certificates
or telegraphic or telephonic confirmations of public officials as well as the
Officer's Certificate and other certificates, documents, statements and other
information of the Company, Oasis Martinique or representatives or officers
thereof.

         For purposes of rendering our opinion, we have not made an independent
investigation or audit of any of the facts set forth in any of the
above-referenced documents, including the Registration Statement and the
Officer's Certificate. We have consequently relied upon your representations
that the information presented in such documents or otherwise furnished to us
accurately and completely describes all material facts relevant to our
opinions.

         Our opinions are based solely on the above-referenced documents that
we have examined; the additional information that we have obtained, and the
representations that have been made to us, and cannot be relied upon if any
fact contained in such documents or in such additional information is, or later
becomes, inaccurate or if any representation made to us is, or later becomes,
inaccurate. Any inaccuracy in, or breach of, any of the aforementioned
documents, statements, representations, warranties and assumptions or any
change after the date hereof in applicable law could adversely affect our
opinion.

         Based upon, and subject to the foregoing and the next paragraph below
and provided that the Company filed a proper election to be taxed as a real
estate investment trust ("REIT") with its timely filed federal income tax
return for the taxable year ending December 31, 1993, which has not been
terminated or revoked, we are of the opinion that:


         1. The Company has met the requirements for qualification and taxation
as a REIT for each taxable year commencing with the taxable year ended December
31, 1993.


         2. The Company's diversity of equity ownership, operations through the
date hereof and proposed method of operation should allow it to qualify as a
REIT for the 1999 taxable year.

         3. As of the date hereof, Oasis Martinique is treated for federal
income tax purposes as a partnership, and not as an association taxable as a
corporation.

         4. The discussion in the Registration Statement under the heading
"Material Federal Income Tax Consequences" to the extent that it describes
matters of law or legal conclusions, is correct in all material respects.

         We express no opinion with respect to the transactions described
herein and in the Registration Statement other than those set forth herein. We
assume no obligation to advise you of any changes in our opinion subsequent to
the delivery of this opinion letter. The Company's qualification and taxation
as a REIT depend upon the Company's ability to meet on a continuing basis,
through actual annual operating and other results, the various requirements
under the Code with regard to, among other things, the sources of its income,
the composition of its assets, the level of its distributions to shareholders,
and the diversity of its share ownership. Locke Liddell & Sapp LLP will not
review or audit the Company's compliance with these requirements on a
continuing basis. Accordingly, no assurance can be given that the actual
operating results of the Company, Oasis Martinique and the other entities in
which the Company or Oasis Martinique own interests, the sources of their
income, the nature of their assets, the level of distributions to shareholders
and the diversity of share ownership for any given taxable year will satisfy
the requirements under the Code for qualification and taxation as a REIT. An
opinion of counsel merely represents counsel's best judgment with respect to
the probable outcome on the merits and is not binding on the IRS or the courts.
There can be no assurance that positions contrary to our opinions will not be
taken by the IRS, or that a court considering the issues would not hold
contrary to such opinions. No ruling has been (or will be) sought from the IRS
by the Company as to the federal income tax matters addressed in this opinion.



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         This opinion letter has been prepared and furnished to you solely for
use in connection with the filing of the Registration Statement. We hereby
consent to the use and filing of this opinion as an exhibit to the Registration
Statement and to all references to us in the Registration Statement.


                               Very truly yours,



                               /s/ LOCKE LIDDELL & SAPP LLP