EXHIBIT 5.1




July 7, 2004




Board of Directors
Advanced Nutraceuticals, Inc.
106 South University Boulevard, #14
Denver, CO  80209

          Re: Advanced Nutraceuticals, Inc. 1995 Stock Option Plan, as Amended

Ladies and Gentlemen:

We have been requested by Advanced Nutraceuticals, Inc. (the "Company") to issue
a legal opinion in connection with the registration under the Securities Act of
1933 on Form S-8 of 1,250,000 shares of the Company's Common Stock, $0.01 par
value (the "Shares"), to be issued under the Company's 1995 Stock Option Plan,
as amended (the "Plan"). We have made such legal and factual examinations and
inquiries as we deemed advisable for the purpose of rendering this opinion. In
our examination, we have assumed and have not verified (i) the genuineness of
all signatures, (ii) the authenticity of all documents submitted to us as
originals, (iii) the conformity with the originals of all documents supplied to
us as copies, and (iv) the accuracy and completeness of all corporate records
and documents and of all certificates and statements of fact, in each case given
or made available to us by the Company.

Based on the foregoing and limited in all respects to Texas law, it is our
opinion that the Shares reserved under the Plan have been duly authorized and
upon payment for and issuance of the Shares in the manner described in the Plan,
will be legally issued, fully paid and nonassessable.

We hereby consent to the filing of this opinion as an exhibit to the Company's
Registration Statement on Form S-8.

Sincerely,



PATTON BOGGS LLP