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                                                                     EXHIBIT 5.1


                             BAKER & HOSTETLER LLP
                           Capitol Square, Suite 2100
                              65 East State Street
                           Columbus, Ohio 43215-4260
                                 (614) 228-1541
                                _________, 2000





BancFirst Ohio Corp.
BFOH Capital Trust I
422 Main Street
Zanesville, Ohio  43701


Ladies and Gentlemen:

         In connection with the registration under the Securities Act of 1933,as
amended (the "Act"), of $20,000,000 aggregate principal amount of Exchange
Junior Subordinated Deferrable Interest Debentures (the "Debt Securities") of
BancFirst Ohio Corp., an Ohio corporation (the "Company"), $20,000,000 aggregate
liquidation amount of Exchange Capital Securities (the"Exchange Capital
Securities") of BFOH Capital Trust I, a business trust created under the laws of
the State of Delaware (the "Issuer"), and the Exchange Guarantee with respect to
the Exchange Capital Securities (the "Guarantee") to be executed and delivered
by the Company for the benefit of the holders from time to time of the Exchange
Capital Securities, we, as your counsel, have examined such corporate records,
certificates and other documents, and such questions of law, as we have
considered necessary or appropriate for the purposes of this opinion.

         Upon the basis of such examination, we advise you that, when:

         (i)      the Registration Statement relating to the Debt Securities,
                  the Exchange Capital Securities and the Exchange Guarantee has
                  become effective under the Act;

        (ii)      the Exchange Guarantee Agreement relating to the Exchange
                  Guarantee with respect to the Exchange Capital Securities of
                  the Issuer has been duly executed and delivered;

         (iii)    the Debt Securities have been duly executed and authenticated
                  in accordance with the Indenture and issued and delivered as
                  contemplated in the Registration Statement; and

         (iv)     the Exchange Capital Securities have been duly executed in
                  accordance with the Amended and Restated Declaration of Trust
                  of the Issuer and issued and delivered as contemplated in the
                  Registration Statement,

         the Debt Securities and the Exchange Guarantee relating to the Exchange
         Capital Securities of the Issuer will constitute valid and legally
         binding obligations of the Company, subject to bankruptcy, insolvency,
         fraudulent transfer, reorganization, moratorium and similar laws of
         general applicability relating to or affecting creditors' rights and to
         general equity principles. Board of Directors BancFirst Ohio Corp.



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         We understand that you have received an opinion regarding the Exchange
Capital Securities from Morris, James, Hitchens & Williams LLP, special Delaware
counsel for the Company and the Issuer. We are expressing no opinion with
respect to the matters contained in such opinion.

         Also, we have relied as to certain Company matters on information
obtained from public officials, officers of the Company and other sources
believed by us to be responsible.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the references to us under the heading "Legal
Matters" in the Prospectus. In giving such consent, we do not thereby admit that
we are in the category of persons whose consent is required under Section 7 of
the Act.


                                   Very truly yours,



                                   Baker & Hostetler LLP



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