Exhibit 5.1

                       OPINION OF LOCKE LIDDELL & SAPP LLP

                               September 15, 2000

Comstock Resources, Inc.
5300 Town & Country Boulevard
Suite 500
Frisco, Texas 75304

      Re:  Registration Statement on Form S-3

Ladies & Gentlemen:

     We have acted as counsel for Comstock Resources, Inc., a Nevada corporation
(the "Company"), in connection with the registration under the Securities Act of
1933,  as amended  (the  "Act"),  of an  aggregate  of  7,500,000  shares of the
Company's  common stock,  $.50 par value per share (the  "Securities").  We have
examined  such  documents  and  questions of law as we have deemed  necessary to
render the opinion expressed below.

     Based upon the foregoing,  we are of the opinion that the Securities,  when
issued and sold as described  in the  above-referenced  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 and to the reference to our firm in the  prospectus  under the caption
"Legal  Matters." In giving this  consent,  we do not thereby admit that we come
within the category of persons whose consent is required  under Section 7 of the
Act or the rules and  regulations  of the  Securities  and  Exchange  Commission
promulgated thereunder.

                                                    Sincerely,

                                                    LOCKE LIDDEL & SAPP LLP





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