Exhibit 5.1

Robert H. Jaffe & Associates, P.A.
8 Mountain Avenue                                              Tel. 973.467.2246
Springfield, New Jersey                                         Fax 973.467.5708
                                October 15, 2003
Suncoast Naturals, Inc.
5422 Carrier Drive
Orlando, Florida 32819

     Re:  Suncoast Naturals, Inc.; Registration Statement Form Sb-2,
          Registration No. 333-107826

Ladies and Gentlemen:

          On the date hereof, Suncoast Naturals, Inc., a Delaware corporation
(the "Company"), intends to transmit to the Securities and Exchange Commission
(the "Commission") a Registration Statement on Form SB-2 (the "Registration
Statement"), relating to 1,850,000 shares of the Company's common stock, $0.001
par value per share (the "Common Stock"), consisting of 750,000 shares of Common
Stock outstanding (the "Outstanding Shares") and 1,100,000 shares of Common
Stock issuable upon exercise of certain warrants (the "Warrant Shares") and
together with the Outstanding Shares, (the "Shares"). This opinion is an exhibit
to the Registration Statement.

          We have at times acted as special counsel to the Company with respect
to certain corporate and securities matters, and in such capacity we are
familiar with the various corporate and other proceedings taken by or on behalf
of the Company in connection with the proposed offering contemplated by the
Registration Statement. However, we are not general counsel to the Company and
would not ordinarily be familiar with or aware of matters relating to the
Company unless they are brought to our attention by its representatives.

          In connection with this opinion, we have examined and are familiar
with originals or copies, certified, or otherwise identified to our
satisfaction, of the Registration Statement, the Certificate of Incorporation
and Bylaws of the Company, the records of corporate proceedings of the Company
and such other statutes, certificates, instruments and such other documents
relating to the Company and matters of law as we have deemed necessary to the
issuance of this opinion. In such examination, we have assumed, without
independent investigation, the genuineness of all signatures, the legal capacity
of all individuals who have executed any of the aforesaid documents, the
authenticity of all documents submitted to us as originals, the conformity with
originals of all documents submitted to us as copies (and the authenticity of
the originals of such copies), and that all public records reviewed are accurate
and complete. As to factual matters, we have relied upon statements or
representations of officers and other representatives of the Company, public
officials or others and have not independently verified the matters stated
therein. Insofar as this opinion relates to securities to be issued in the
future, we have assumed that all applicable laws, rules and regulations in
effect at the time of such issuance are the same as such laws, rules and
regulations in effect as of the date hereof.








Suncoast Naturals, Inc.
October 15, 2003
Page 2

          Based upon the foregoing, and subject to and in reliance on the
accuracy and completeness of the information relevant thereto provided to us, we
are of the opinion that in accordance with the laws of the State of Delaware (a)
the Outstanding Shares have been duly authorized and, subject to the
effectiveness of the Registration Statement and compliance with applicable state
securities laws, are legally and validly issued, fully paid and non-assessable
shares of Common Stock, and (b) the Warrant Shares have been duly authorized
and, subject to the effectiveness of the Registration Statement and compliance
with applicable state securities laws, when issued and paid for in accordance
with the terms set forth in the respective warrant agreements relating to the
Warrant Shares, will be legally and validly issued, fully paid and non-
assessable.

         We express no opinion with respect to the laws of any jurisdiction
other than the State of Delaware and the federal laws of the United States
typically applicable to transactions of the type contemplated by the
Registration Statement. Without limiting the generality of the foregoing, we
also express no opinion concerning compliance with the laws or regulations of
any other jurisdiction or jurisdictions. We assume no obligation to supplement
this opinion if any applicable laws change after the date hereof or if we become
aware of any facts that might change the opinions expressed herein after the
date hereof. We express no opinion as to the application of securities or "Blue
Sky" laws of any state, including the State of Delaware, to the offer and/or
sale of the Shares.

          The opinion expressed in this letter is for the use of the Company in
connection with the Registration Statement. This opinion may also be relied on
by potential investors who purchase the Shares. The opinion expressed in this
letter is limited to the matters set forth herein, and no other opinion should
be inferred beyond the matters expressly stated.





Suncoast Naturals, Inc.
October 15, 2003
Page 3

          We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to us under the heading "Legal
Matters" in the Registration Statement. In giving the foregoing consent, we do
not thereby admit that we are in the category of persons whose consent is
required under Section 7 of the Securities Act of 1933, as amended, or the rules
and regulations of the Commission promulgated thereunder.

Very truly yours,

/s/Robert H. Jaffe
- ----------------------
ROBERT H. JAFFE, ESQ.