EXHIBIT 8

     [Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A. Letterhead]


                               May 1, 2003


Whitman Education Group, Inc.
4400 Biscayne Boulevard
Miami, Florida 33137

     Re:       Registration Statement on Form S-4 of Career Education
               Corporation ("CEC") containing the preliminary Proxy
               Statement/Prospectus of Whitman Education Group, Inc. ("Whitman")
               and CEC dated May 1, 2003 (the "Proxy Statement/Prospectus")

Ladies and Gentlemen:

     You have requested our opinion concerning the United States federal income
tax consequences of certain of the transactions (the "Transactions")
contemplated by that certain Agreement and Plan of Merger, dated March 26, 2003,
by and among Whitman, CEC and Marlin Acquisition Corp. (the "Merger Agreement")
described in the Registration Statement, specifically, the United States Federal
income tax consequences of the merger among Whitman, CEC and Marlin Acquisition
Corp. (the "Merger").

     For purposes of our rendering this opinion, we have examined and relied
upon originals or copies, certified or otherwise identified to our satisfaction,
of (i) the Registration Statement, (ii) the Merger Agreement and the schedules
and exhibits thereto, and (iii) such other presently existing documents,
records, and matters of law as we have deemed necessary or appropriate in order
to enable us to render the opinions below. We have assumed as to factual matters
the truth and accuracy at all relevant times of the representations, warranties
and other statements made by Whitman and CEC in connection with the
Transactions, including but not limited to those set forth in the Merger
Agreement and the Registration Statement, and that any such representation,
warranty, or other statement made "to the Knowledge" (or similar qualification)
of any person or party is true and correct without such qualification. We have
also assumed that the Merger will be consummated strictly in accordance with the
terms of the Merger Agreement as they exist on the date hereof, without
modification or waiver thereof.

     Our conclusions represent our judgment as to the proper treatment of
certain aspects of the Transactions under the federal income tax laws of the
United States based upon the Internal Revenue Code of 1986, as amended, Treasury
Regulations, case law, and rulings and other pronouncements of the Internal
Revenue Service as in effect on the date of this opinion.

     Our opinion addresses only the specific United States federal income tax
consequences of the Transactions set forth under the section "Material Federal
Income Tax Consequences," and does not address any other federal, state, local
or foreign income, estate, gift, transfer, sales, use, or other tax consequences
that may result from the Transactions or any other transaction. We express no
opinion regarding the tax consequences of the Transactions to any person or
entity that is subject to special tax rules.



     Based upon and in reliance on the representations and assumptions contained
herein, and subject to the limitations and qualifications set forth herein, we
are of the opinion that the discussion under the section "Material Federal
Income Tax Consequences" in the Registration Statement, subject to the
limitations and qualifications described therein, describes the material United
States federal income tax consequences of the matters described therein.

     This opinion addresses only the effect under the United States federal
income tax laws of the Transactions, and we express no opinion with respect to
the applicability thereto, or the effect thereon, of other federal laws, the
laws of any state or other jurisdiction, or as to any matters of municipal law
or the laws of any other local agencies within any state.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and the reference to our firm and the above-mentioned
opinion under the headings "Material Federal Income Tax Consequences" included
in the Registration Statement. In giving such consent, we do not thereby admit
that we are acting within the category of persons whose consent is required
under Section 7 of the Securities Act and the rules and regulations of the
Securities and Exchange Commission thereunder.


                                            Very truly yours,


                                            /s/ Stearns Weaver Miller Weissler
                                            Alhadeff & Sitterson, P.A.
                                            -----------------------------------
                                            Stearns Weaver Miller Weissler
                                            Alhadeff & Sitterson, P.A.