Exhibit 5.1






                                                       October 7, 2003


Adolph Coors Company,
   311 Tenth Street,
      Golden, Colorado 80401.

Ladies and Gentlemen:

         In connection with the preparation and filing of Post-Effective
Amendment No. 1 to the registration statement on Form S-8 filed on May 21, 1991,
Registration No. 33-40730 (the "Registration Statement"), pursuant to Rule
414(d) of the Securities Act of 1933, as amended (the "Securities Act"),
relating to the registration of shares of Class B Common Stock, par value of
$0.01 per share (the "Securities"), of Adolph Coors Company, a Delaware
corporation (the "Company"), issuable under the Adolph Coors Company Equity
Compensation Plan for Non-Employee Directors (the "Plan"), in connection with,
and upon completion of, a reincorporation merger whereby the Company's
predecessor, Adolph Coors Company, a Colorado corporation ("Coors Colorado"),
merged with and into the Company, its wholly owned Delaware subsidiary, with the
Delaware subsidiary being the surviving corporation (the "Reincorporation
Merger"), we, as counsel to the Company and its predecessor, Coors Colorado,
have examined such corporate records, certificates and other documents, and such
questions of law, as we have considered necessary or appropriate for the
purposes of this opinion. Upon the basis of such examination, it is our opinion
that the Securities have been duly authorized, and when offered and sold
pursuant to the terms and conditions of the Plan, will be validly issued and
fully paid and nonassessable.

         We note that the Company is deemed a 'successor issuer' of Coors
Colorado for purposes of Rule 414(d) under the Securities Act, and may expressly
adopt the Registration Statement of Coors Colorado as its own registration
statement for all purposes of the Securities Act by filing Post-Effective
Amendment No.1 to the Registration Statement. For purpose of the preceding
sentence, we refer you to the no-action relief granted to Coors Colorado by the
Securities and Exchange Commission (the "Commission") in a letter response from
the Commission, dated August 25, 2003.

         The foregoing opinion is limited to the Federal laws of the United
States and the General Corporation Law of the State of Delaware and we are
expressing no opinion as to the effect of the laws of any other jurisdiction.

         We have relied as to certain matters on information obtained from
public officials, officers of the Company and other sources believed by us to be
responsible.

         We hereby consent to the filing of this opinion as an exhibit to the
Post-Effective Amendment No.1 to the Registration Statement. In giving such
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.

                                            Very truly yours,
                                            Sullivan & Cromwell LLP