Exhibit 5.1



                                    June 25, 1998




Cumulus Media Inc.
330 East Kilbourn Avenue
Milwaukee, WI 53202

Ladies and Gentlemen:

          We have acted as special counsel for Cumulus Media Inc., an Illinois
corporation (the "Company"), in connection with the Company's Registration
Statement on Form S-1, as amended (the "Registration Statement") being filed by
the Company under the Securities Act of 1933, as amended, relating to the offer
and sale of up to 7,420,000 shares (the "Shares") of the Company's Class A
common stock, par value $.01 per share (the "Common Stock") and 125,000 shares
(the "Preferred Shares") of the Company's Series A Cumulative Exchangeable
Redeemable Preferred Stock due 2009.  Of the Shares, 937,500 are subject to an
option granted to the underwriters by the Company to cover over-allotments, if
any.  

          In connection with this letter, we have examined, considered and
relied solely upon the following documents (collectively, the "Documents"):  the
Registration Statement; the form of the Company's Amended and Restated Articles
of Incorporation; the form of the Company's Bylaws; certain written consent
resolutions of the Company's Board of Directors and shareholders; a certificate
of the Company's secretary; and such matters of law as we have considered
necessary or appropriate for the expression of the opinions contained herein. 

          In rendering the opinions set forth below, we have assumed without
investigation the genuineness of all signatures and the authenticity of all
documents submitted to us as originals, the conformity to authentic original
documents of all documents submitted to us as copies, and the veracity of the
Documents.  As to questions of fact material to the opinions hereinafter
expressed, we have relied upon the representations and warranties of the Company
made in the Documents.




Cumulus Media Inc.
June 25, 1998
Page 2


          Based solely upon and subject to the Documents, and subject to the
qualification set forth below, we are of the opinion that the Shares and the
Preferred Shares, when duly delivered against payment therefor, as contemplated
by the Registration Statement, will be duly authorized, validly issued, fully
paid and non-assessable.  

          This opinion letter is limited to the matters stated herein and no
opinions may be implied or inferred beyond the matters expressly stated herein. 
The opinions expressed herein are as of the date hereof, and we assume no
obligation to update or supplement such opinions to reflect any facts or
circumstances that may hereafter come to our attention or any changes in law
that may hereafter occur.

          We hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement and to the reference to us under the caption "Legal
Matters" in the prospectus contained in the Registration Statement.


                                             Very truly yours,

                                             /s/ HOLLEB & COFF