Exhibit 5.1 REED SMITH SHAW & MCCLAY LLP 1301 K Street, N.W. Suite 1100 - East Tower Washington, D.C. 20005-3317 Phone: 202-414-9200 Fax: 202-414-9299 April 30, 1999 Phoenix Healthcare Corporation 4514 Travis Street, Suite 330 Dallas, Texas 75205 Re: Registration Statement on Form S-8 for Stock to be Issued Under the Phoenix Healthcare Corporation 1999 Stock Option Plan, Stock Purchase Plan and Share Award Plan, and Pursuant to Certain Employment Agreements (the "Plans") Gentlemen: We have acted as counsel to Phoenix Healthcare Corporation (the "Company") in connection with the above-captioned Registration Statement relating to 14,400,000 shares of the Common Stock, par value $.001, of the Company (the "Shares") which may be offered or sold to certain employees, directors and consultants of the Company and its affiliates under the Plans. The Plans provide that either unissued or reacquired Shares, or any combination thereof, may be awarded under the Plans. In rendering our opinion below, we have assumed that any previously issued Shares reacquired by the Company and used under the Plans were duly authorized, validly issued and fully paid at the time of their original issuance. In connection with this opinion, we have examined such records of the Company and other documents as we have determined relevant and necessary as the basis for the opinion set forth below. In such examination, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as certified or photostatic copies, and the authenticity of the originals of such copies. Based upon the foregoing and upon an examination of such other documents, corporate proceedings, statutes, decisions and questions of law as we considered necessary in order to enable us to furnish this opinion, and subject to the assumption set forth above, we are pleased to advise you that in our opinion: (a) The Company has been duly formed and is a validly existing corporation under the laws of the State of Delaware; and (b) The Shares being registered and which may be offered or sold by the Company pursuant to the provisions of the Plans have been duly authorized, and upon such sale in accordance with the provisions of the Plans such Shares will be validly issued, fully paid and nonassessable. REED SMITH SHAW & MCCLAY LLP Phoenix Healthcare Corporation April 30, 1999 Page 2 We hereby consent to the filing of this opinion as an Exhibit to the Registration Statement and to the use of our name in the Prospectus under the caption "Legal Opinion". Very truly yours, Reed Smith Shaw & McClay LLP