EXHIBIT 5.1





                                April 16, 2002

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

      Re:  Registration of $1,000,000,000 of Debt Securities

Ladies and Gentlemen:

      I have acted as counsel for SunTrust Banks, Inc., a Georgia corporation
("SunTrust"), in connection with the registration pursuant to a registration
statement on Form S-3 (the "Registration Statement") filed by SunTrust with the
Securities and Exchange Commission under the Securities Act of 1933, as amended
(the "Act"), of $1,000,000,000 aggregate principal amount of either (i) Senior
Debt Securities of SunTrust (the "Senior Debt Securities"), to be issued
pursuant to that certain Indenture (the "Senior Indenture"), dated as of May 1,
1993, between SunTrust and J.P. Morgan Trust Company, National Association, as
successor to PNC Bank, National Association, as Trustee (the "Senior Trustee")
or (ii) Subordinated Debt Securities of SunTrust (the "Subordinated Debt
Securities") to be issued pursuant to that certain Indenture (the "Subordinated
Indenture"), dated as of May 1, 1993, between SunTrust and Bank One, N.A., as
successor to The First National Bank of Chicago, as Trustee (the "Subordinated
Trustee").

      In so acting, I have examined and relied upon the accuracy of original,
certified, conformed or photographic copies of such records, agreements,
certificates and other documents as I have deemed necessary or appropriate to
enable me to render the opinions set forth below. In all such examination, I
have assumed the genuineness of signatures on original documents and the
conformity to such original documents of all copies submitted to me as
certified, conformed or photographic copies and, as to certificates of public
officials, I have assumed the same to have been properly given and to be
accurate.

      I have assumed that the execution and delivery of, and the performance of
all obligations under, the Senior Indenture and the Subordinated Indenture have
been duly authorized by all requisite action by each party thereto (other than
SunTrust), and that such documents are the valid and binding agreements of each
party thereto (other than SunTrust) enforceable against each party thereto
(other than SunTrust) in accordance with their respective terms.

            This opinion is limited in all respects to the laws of the State of
      Georgia, and no opinion is expressed with respect to the laws of any other
      jurisdiction or any effect that such laws may have on the opinions
      expressed herein. This opinion is limited to the matters stated herein,
      and no opinion is implied or may be inferred beyond the matters expressly
      stated herein.

      Based upon the foregoing, I am of the opinion that:

            (i)   The Senior Indenture has been duly authorized, executed and
      delivered by SunTrust and constitutes the valid and binding obligation of
      SunTrust enforceable against SunTrust in accordance with its terms
      subject, as to the enforcement of remedies, to bankruptcy,

      insolvency, reorganization, moratorium and similar laws affecting the
      rights and remedies of creditors generally and to the effect of general
      principles of equity;

            (ii)  The Subordinated Indenture has been duly authorized, executed
      and delivered by SunTrust and constitutes the valid and binding obligation
      of SunTrust enforceable against SunTrust in accordance with its terms
      subject, as to the enforcement of remedies, to bankruptcy, insolvency,
      reorganization, moratorium and similar laws affecting the rights and
      remedies of creditors generally and to the effect of general principles of
      equity;

            (iii) The Senior Debt Securities, when the definitive terms and
      provisions thereof have been established and when executed and delivered
      by SunTrust and authenticated by the Senior Trustee under the Senior
      Indenture and delivered to and paid for by the purchasers thereof, will be
      validly issued and will constitute valid and binding obligations of
      SunTrust enforceable against SunTrust in accordance with their terms
      subject, as to the enforcement of remedies, to bankruptcy, insolvency,
      reorganization, moratorium and similar laws affecting the rights and
      remedies of creditors generally and to the effect of general principles of
      equity; and

            (iv)  The Subordinated Debt Securities, when the definitive terms
      and provisions thereof have been established and when executed and
      delivered by SunTrust and authenticated by the Subordinated Trustee under
      the Subordinated Indenture and delivered to and paid for by the purchasers
      thereof, will be validly issued and will constitute valid and binding
      obligations of SunTrust enforceable against SunTrust in accordance with
      their terms subject, as to the enforcement of remedies, to bankruptcy,
      insolvency, reorganization, moratorium and similar laws affecting the
      rights and remedies of creditors generally and to the effect of general
      principles of equity.

      This opinion is given as of the date hereof, and I assume no obligation to
update this opinion to reflect any fact or circumstance that may hereafter come
to my attention or any change in any law or regulation that may hereafter occur.

      I consent to the filing of this opinion as an exhibit to the Registration
Statement and to the reference to me under the caption "Legal Matters" in the
prospectus that forms a part thereof. In giving such consent, I do not thereby
admit that I am in the category of persons whose consent is required under
Section 7 of the Act.

                                    Sincerely,

                                           /s/ Raymond D. Fortin
                                    -------------------------------------------
                                    Name:  Raymond D. Fortin
                                    Title: Senior Vice President, General
                                           Counsel and Corporate Secretary