EXHIBIT 5.1
                                                                     -----------

                                October 29, 2001

Hooper Holmes, Inc.
170 Mt. Airy Road
Basking Ridge, New Jersey 07920


               Re: Registration Statement on Form S-8
                   ----------------------------------

Gentlemen:

               In connection with the registration under the Securities Act of
1933, as amended, of 2,000,000 shares of Common Stock (the "Shares") of Hooper
Holmes, Inc. (the "Company"), we have examined the Registration Statement on
Form S-8 to be filed by the Company with the Securities and Exchange Commission
(the "Registration Statement"), corporate records, certificates of public
officials, and such other documents as we deemed appropriate or necessary for
the purpose of rendering this opinion.

               Based on the foregoing, it is our opinion that the Shares of the
Company covered by the Registration Statement have been duly authorized, and,
when issued, will be legally issued, fully paid and nonassessable.

               We consent to the filing of this opinion as an exhibit to the
Registration Statement, and to the reference to our firm under the caption
"Legal Matters" in the Prospectus.

                                       Very truly yours,

                                       /s/ Steptoe & Johnson LLP

                                       STEPTOE & JOHNSON LLP