EXHIBIT 5


KILPATRICK STOCKTON LLP                            Suite 2800 1100 Peachtree St.
                                                           Atlanta GA 30309-4530
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                                                      www.KilpatrickStockton.com

                                                        direct dial 404 815 6570
                                                         direct fax 404 541 3151
January 22, 2003                                RCheatham@KilpatrickStockton.com



United Community Banks, Inc.
63 Highway 515
Blairsville, Georgia 30512

         Re:      United Community Banks, Inc.
                  Registration Statement on S-4 (File No. 333-_____)

Gentlemen:

         At your request,  we have examined the  Registration  Statement on Form
S-4 (the  "Registration  Statement")  filed by United Community Banks, Inc. (the
"Company"),  a Georgia corporation,  with the Securities and Exchange Commission
with respect to the  registration  under the Securities Act of 1933, as amended,
of 821,579 shares of common stock, par value $1.00 per share of the Company (the
"Common  Stock"),  to be  issued by the  Company  to the  shareholders  of First
Central  Bancshares,  Inc. ("First  Central"),  in connection with the merger of
First Central with and into the Company.

         As  your  counsel,  and  in  connection  with  the  preparation  of the
Registration  Statement,  we have  examined  the  originals  or  copies  of such
documents,  corporate records,  certificates of public officials and officers of
the Company,  and other instruments related to the authorization and issuance of
the Common Stock as we deemed  relevant or necessary  for the opinion  expressed
herein.  Based upon the  foregoing,  it is our opinion that the shares of Common
Stock to be issued by the  Company to the First  Central  shareholders  will be,
upon  issuance,  sale,  and  delivery  in the  manner  and  under  the terms and
conditions described in the Registration Statement,  validly issued, fully paid,
and nonassessable.

         We hereby  consent  to the use of this  opinion  as an  exhibit  to the
Registration  Statement and further consent to the use of our name in the "Legal
Matters"  section  of  the  Registration  Statement,  including  the  Prospectus
constitution a part thereof, and any amendments thereto.

                                            Sincerely,

                                            KILPATRICK STOCKTON LLP



                                            By: /s/ Richard R. Cheatham
                                               ---------------------------------
                                                  Richard R. Cheatham, a Partner