Exhibit 5.1

                         Citizens Communications Company
                                3 High Ridge Road
                               Stamford, CT 06905
                                 (203) 614-5600


                                  May 29, 2008


Citizens Communications Company
3 High Ridge Park
Stamford, CT  06905

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

Ladies and Gentlemen:

     I have acted as counsel to Citizens  Communications Company (the "Company")
in connection  with the  preparation and filing with the Securities and Exchange
Commission   of  the   Company's   Registration   Statement  on  Form  S-8  (the
"Registration  Statement")  under the Securities  Act of 1933, as amended,  with
respect to 3,000,000  shares of the Company's  common stock, par value $0.25 per
share (the "Common  Stock"),  that may be issued under the terms of the Citizens
Communications  Company  Amended and Restated  2000 Equity  Incentive  Plan (the
"Plan").

     In so acting, I have examined  originals or copies  (certified or otherwise
identified to my satisfaction) of the Registration  Statement and such corporate
records,  agreements,  documents and other instruments, and such certificates or
comparable  documents of public officials and of officers and representatives of
the Company,  and have made such inquiries of such officers and  representatives
as I have deemed relevant and necessary as a basis for the opinions  hereinafter
set forth.

     In such examination,  I have assumed the genuineness of all signatures, the
legal  capacity  of all  natural  persons,  the  authenticity  of all  documents
submitted  to me as  originals,  the  conformity  to original  documents  of all
documents submitted to me as certified,  conformed or photostatic copies and the
authenticity of the originals of such latter  documents.  As to all questions of
fact material to these opinions that have not been independently  established, I
have  relied  upon   certificates  or  comparable   documents  of  officers  and
representatives of the Company.

     Based on the foregoing,  and subject to the qualifications stated herein, I
am of the opinion  that the Common  Stock to be issued  pursuant to the terms of
the Plan have been duly authorized  and, when issued,  delivered and paid for in
accordance with the terms of the Plan,  will be validly  issued,  fully paid and
non-assessable.  The opinions expressed herein are limited to the corporate laws
of the State of  Delaware  and the  federal  laws of the  United  States,  and I
express no opinion as to the effect on the  matters  covered by this  opinion of
the laws of any other jurisdiction.



     I  hereby  consent  to  the  use  of  this  letter  as an  exhibit  to  the
Registration Statement.

                                  Very truly yours,

                                  /s/ Hilary E. Glassman

                                  Hilary E. Glassman
                                  Senior Vice President, General Counsel and
                                  Secretary
                                  Admitted in New York only