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                       [BAKER & HOSTETLER LLP LETTERHEAD]

                                   EXHIBIT 5.1

                              FORM OF LEGAL OPINION

                                ___________, 2000


BancFirst Ohio Corp.
422 Main Street
P.O. Box 4658
Zanesville, Ohio  43702

Gentlemen:

         We are familiar with your Articles of Incorporation, Code of
Regulations and corporate proceedings. On this basis, we have made an
examination as to:

         1. The organization of BancFirst Ohio Corp.;

         2. The legal sufficiency of all corporate proceedings of BancFirst Ohio
Corp. in connection with the authorization and issuance of all presently
outstanding and issued Common Stock of BancFirst Ohio Corp.; and

         3. The legal sufficiency of all corporate proceedings taken in
connection with the authorization of the issuance of shares of Common Stock
pursuant to an Agreement and Plan of Reorganization dated as of January 13, 2000
among BancFirst Ohio Corp., The First National Bank of Zanesville, Milton
Federal Financial Corporation and Milton Federal Savings Bank and included in a
Registration Statement on Form S-4 filed with the Securities and Exchange
Commission in connection with that Agreement.

          Based upon such examination, we are of the opinion that:

         1. BancFirst Ohio Corp. is a duly organized and validly existing
corporation under the laws of the State of Ohio;

         2. BancFirst Ohio Corp. has taken all necessary and required corporate
actions in connection with the issuance of Common Stock pursuant to the
Agreement and Plan of Reorganization dated as of January 13, 2000 among
BancFirst Ohio Corp., The First National Bank of Zanesville, Milton Federal
Financial Corporation and Milton Federal Savings Bank, and when issued, those
shares of Common Stock will be validly authorized, legally issued, fully paid
and nonassessable shares of Common Stock of BancFirst Ohio Corp. free of any
preemptive rights.

         We hereby consent to the reference to our firm in the Registration
Statement and the Prospectus as the attorneys who will pass upon legal matters
in connection with the issuance of such shares of Common Stock and to the filing
of this opinion as an exhibit to the Registration Statement. In providing this
consent, we do not admit that we are within the category of persons whose
consent is required under Section 7 of the Securities Act of 1933 or the rules
and regulations of the Commission promulgated thereunder.


                                              Very truly yours,

                                              BAKER & HOSTETLER, LLP