November 10, 1999



CEL-SCI Corporation
8229 Boone Blvd., Suite 802
Vienna,  Virginia 22182


 Gentlemen:

          This letter will  constitute  an opinion upon the legality of the sale
 by CEL-SCI Corporation, a Colorado corporation,  of up to 340,000 shares of
 Common Stock, all as referred to in the Registration  Statement on Form S-8
 filed by the Company with the Securities and Exchange Commission.

         We have  examined  the  Articles of  Incorporation,  the Bylaws and the
minutes of the Board of Directors of the Company and the applicable  laws of the
State of Colorado, and a copy of the Registration Statement. In our opinion, the
Company has duly  authorized the issuance of the shares of stock mentioned above
and  such  shares  when  issued  will  be  legally   issued,   fully  paid,  and
nonassessable.

                                  Very truly yours,

                                  HART & TRINEN


                                  By  /s/ William T. Hart
                                       William T. Hart