Exhibit 5


                        [Capitol Bancorp Ltd. Letterhead]

                                September 5, 2002

Capitol Bancorp Ltd.
Capitol Bancorp Center, 200 N. Washington Square
Lansing, Michigan 48933

Ladies and Gentlemen:

     With respect to the registration  statement on Form S-8 (the  "Registration
Statement") being filed on this date with the Securities and Exchange Commission
(the  "Commission")  by  Capitol  Bancorp  Ltd.,  a  Michigan  corporation  (the
"Company"),  for the purpose of registering under the Securities Act of 1933, as
amended (the "Act"),  an indeterminate  amount of interests in the Sun Community
Bancorp  Limited  Amended and  Restated  Stock  Incentive  Plan (the "Plan") and
984,766  shares  of  the  common  stock,  no par  value,  of  the  Company  (the
"Registered Shares"), which may consist of shares already issued or newly issued
shares, we, as your counsel, have examined such certificates,  instruments,  and
documents  and  have  reviewed  such  questions  of  law as we  have  considered
necessary or appropriate for the purposes of this opinion,  and, on the basis of
such examination and review, we advise you that, in our opinion:

     1. The Registered Shares have been duly authorized.

     2. When the  Registration  Statement has become  effective  and  Registered
Shares have been issued,  sold and paid for in  accordance  with the Plan,  said
Registered Shares will be validly issued, fully paid, and nonassessable.

     I hereby  consent  to the  filing  of this  opinion  as an  exhibit  to the
Registration Statement. In giving this consent, I do not thereby admit that I am
within the category of persons whose consent is required  under Section 7 of the
Act or the rules and regulations of the Commission.


                                        Very truly yours,

                                        /s/ Cristin Reid English
                                        -------------------------------
                                        Cristin Reid English
                                        Chief Administrative Officer