[THE LEBRECHT GROUP, APLC LETTERHEAD]


                                March 3, 2003


TMI  Holdings,  Inc.
4463  Pahe'e  Street,  Suite  203-B
Lihue,  HI  96766


Ladies  and  Gentlemen:

     You have requested our opinion as counsel for TMI Holdings, Inc., a Florida
corporation  (the  "Company")  in  connection  with  the  registration under the
Securities  Act  of  1933, as amended, and the Rules and Regulations promulgated
thereunder,  and  the  public offering by the Company of up to 250,000 shares of
Company  common  stock  issuable  to  consultants  of  the  Company.

     We  have  examined  the Company's Registration Statement on Form S-8 in the
form  to  be filed with the Securities and Exchange Commission on or about March
3, 2003 (the "Registration Statement"). We further have examined the Amended and
Restated  Articles  of  Incorporation,  Bylaws,  and  applicable  minutes of the
Company  as  a  basis  for  the  opinion  hereafter  expressed.

     Based  on  the  foregoing  examination,  we  are  of the opinion that, upon
issuance  and  sale  in  the manner described in the Registration Statement, the
shares  of  common  stock  covered by the Registration Statement will be legally
issued,  fully  paid,  and  nonassessable.

     We  consent to the filing of this opinion as an exhibit to the Registration
Statement.

                         Sincerely,

                         /s/  The  Lebrecht  Group,  APLC

                         The  Lebrecht  Group,  APLC