EXHIBIT 5.1

                                October 26, 2001


Service Corporation International
1929 Allen Parkway
Houston, Texas  77019

Ladies and Gentlemen:

         We have acted as counsel for Service Corporation International., a
Texas corporation (the "Company"), in connection with the filing of the
Registration Statement on Form S-3 (the "Registration Statement") with respect
to the registration of 6,000,000 shares (the "Shares") of the Common Stock,
$1.00 par value (the "Common Stock"), of the Company.

         In connection with the foregoing, we have examined or are familiar with
the corporate records of the Company, including its Restated Articles of
Incorporation, its Bylaws and resolutions its directors. We have also examined
the Registration Statement of the Company, including the related prospectus and
other attachments, filed with the Securities and Exchange Commission to register
the Shares under the Securities Act of 1933, as amended (the "Securities Act").

         We have assumed the genuineness and authenticity of all signatures on
all original documents, the authenticity of all documents submitted to us as
originals, the conformity to originals of all documents submitted to us as
copies and the due authorization, execution, delivery or recordation of all
documents where due authorization, execution or recordation are prerequisites to
the effectiveness thereof.

         Based upon the foregoing, and having due regard for such legal
considerations as we deem relevant, we are of the opinion that the Shares have
been duly authorized and are validly issued, fully paid and nonassessable.

         The foregoing opinions are limited to the laws of the United States of
America and the State of Texas. For purposes of this opinion, we assume that the
Shares will be issued in compliance with all applicable state securities or Blue
Sky laws.

         We hereby consent to the filing of this opinion with the Securities and
Exchange Commission as an exhibit to the Registration Statement and to the
statements made regarding our Firm and to the use of our name under the heading
"Legal Matters" in the prospectus constituting a part of the Registration
Statement. In giving this consent, we do not admit that we are within the
category of persons whose consent is required under Section 7 of the Securities
Act and the rules and regulations thereunder.


                            LOCKE LIDDELL & SAPP LLP


                            By: /s/ DAVID F. TAYLOR
                               --------------------------
                                 David F. Taylor