EXHIBIT 8

                         [KING & SPALDING LETTERHEAD]




                                April 2, 1998




Magellan Health Services, Inc.
3414 Peachtree Road N.E.
Suite 1400
Atlanta, Georgia 30326

Ladies and Gentlemen:

     We have acted as counsel to Magellan Health Services, Inc., a Delaware 
corporation ("the Company"), in connection with the Prospectus (the 
"Prospectus") that forms a part of the Registration Statement on Form S-4 
that was filed by the Company on March 13, 1998 with the Securities and 
Exchange Commission (the "Registration Statement"), relating to the 
registration of the Company's 9% Series A Senior Subordinated Notes due 2008 
(the "Notes").

     All capitalized terms used herein without definition have the respective 
meanings specified in the Prospectus.

     You have requested our opinion with respect to the description contained 
in the Prospectus of the federal income tax consequences of the exchange (the 
"Exchange") of the Notes for the Company's outstanding 9% Senior Subordinated 
Notes due 2008 (the "Old Notes"). We understand that our opinion will be 
attached as an Exhibit to the Registration Statement and that our opinion 
will be referred to in the Prospectus. We hereby consent to such use of our 
opinion.

     In rendering the opinion expressed herein, we have examined such 
documents as we have deemed appropriate, including the Prospectus. In our 
examination of documents, we have assumed, with your consent, that all 
documents submitted to us are authentic originals, or if submitted as 
photocopies, that they faithfully reproduce the originals thereof, that all 
such documents have been or will be duly executed to the extent required, 
that all representations and statements set forth in such documents are true 
and correct, and that all obligations imposed by any such documents on the 
parties thereto have been or will be performed or satisfied in accordance 
with their terms. We also have obtained such additional information and 
representations as we have deemed relevant and necessary.



Magellan Health Services, Inc.
April 2, 1998
Page 2


     Based upon and subject to the foregoing, it is our opinion that the 
material federal income tax consequences of the Exchange to the holders of 
the Old Notes are fairly and accurately described in the Prospectus under the 
caption "Certain Federal Income Tax Consequences of the Exchange Offer."

     The opinion expressed herein is based upon existing statutory, 
regulatory and judicial authority, any of which may be changed at any time 
with retroactive effect. In addition, as noted above, our opinion is based 
solely on the documents that we have examined, the additional information 
that we have obtained, and the representations that have been made to us. Our 
opinion cannot be relied upon if any of the facts contained in such documents 
or such additional information is, or later becomes, inaccurate or if any of 
the representations made to us is, or later becomes, inaccurate.

     Finally, our opinion is limited to the tax matters specifically 
discussed under the caption "Certain Federal Income Tax Consequences of the 
Exchange Offer" in the Prospectus, and we have not been asked to address, nor 
have we addressed, any other tax consequences relating to the issuance or 
sale of the Notes.

                                           Very truly yours,


                                           /s/ KING & SPALDING
                                           -----------------------------------
                                               King & Spalding