Exhibit 5.1

                                  July 16, 1999



ResortQuest International, Inc.
1355-B Lynnfield Road
Suite 245
Memphis, TN  38119

         RE:      Shelf Registration Statement on Form S-4

Ladies and Gentlemen:

         We have acted as counsel to ResortQuest International, Inc., a Delaware
corporation (the "Company"), in connection with the filing of a Shelf
Registration Statement on Form S-4, including the exhibits thereto (the
"Registration Statement"), under the Securities Act of 1933, as amended (the
"Act"), for the registration by the Company of 5,000,000 shares (the "Shares")
of Common Stock, par value $.01 per share, which may be issued (i) to the
Selling Stockholders (as such term is defined in the Registration Statement) and
(ii) from time to time in connection with the acquisition by the Company of
other businesses, and which may be reserved for issuance pursuant to, or offered
and issued upon exercise or conversion of, warrants, options, convertible notes
or other similar instruments ("Other Securities") issued by the Company from
time to time in connection with any such acquisition.

         In connection with this opinion, we have examined originals, or copies
certified or otherwise identified to our satisfaction, of the Registration
Statement and such other documents





and records as we have deemed necessary. We have assumed that (i) the
Registration Statement, and any amendments thereto, will have become effective;
and (ii) all Shares will be issued in compliance with applicable federal and
state securities laws.

         With respect to the issuance of any Shares, we have assumed that the
issuance of such Shares will have been duly authorized and, if applicable, such
Shares will have been reserved for issuance upon the exercise or conversion of
Other Securities; and we have further assumed that the Shares will have been
issued, and the certificates evidencing the same will have been duly executed
and delivered, against receipt of the consideration approved by the Company
which will be no less than the par value thereof.

         Based upon the foregoing, we are of the opinion that, upon issuance,
all of the Shares will be duly authorized and validly issued, fully paid and
non-assessable.

         The foregoing opinion is limited to the laws of the State of Delaware.

         We consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the caption "Legal
Matters." In giving this consent, we do not admit that we are acting within
the category of persons whose consent is required under Section 7 of the Act.

                                       Sincerely,


                                       AKIN, GUMP, STRAUSS, HAUER & FELD, L.L.P.