Exhibit 5.1



                                February 12, 2003

Alabama Power Company
600 North 18th Street
Birmingham, AL  35291

         RE:  Registration Statement on Form S-3

Ladies and Gentlemen:

         We have acted as counsel to Alabama Power Company (the "Company") in
connection with the Registration Statement on Form S-3 (Registration Statement
Nos. 333-100721, 333-100721-01, 333-100721-02 and 333-100721-03) filed with the
Securities and Exchange Commission (the "Commission") on October 24, 2002 and
declared effective by the Commission on November 6, 2002 (the "Registration
Statement"), under the Securities Act of 1933, as amended (the "Act"), relating
to 1,250 shares of Flexible Money Market Class A Preferred Stock (Series 2003A),
cumulative, par value $1 per share (stated capital $100,000 per share) of the
Company (the "Preferred Stock") issued pursuant to the Company's Joint Agreement
between Alabama Power Company, Gulf Electric Company and Houston Power Company
dated October 3, 1927 pursuant to which the Company was formed (as heretofore
amended, including the amendment setting for the rights and preferences of the
Preferred Stock dated February 6, 2003, the "Charter").

         We have examined the Registration Statement and the Charter. We have
also examined the originals, or duplicates or certified or conformed copies, of
such records, agreements, instruments and other documents and have made such
other and further investigations as we have deemed relevant and necessary in
connection with the opinions expressed herein. As to questions of fact material
to this opinion, we have relied upon certificates of public officials and of
officers and representatives of the Company.

         In rendering the opinions set forth below, we have assumed the
genuineness of all signatures, the legal capacity of natural persons, the
authenticity of all documents submitted to us as originals, the conformity to
original documents of all documents submitted to us as duplicates or certified
or conformed copies and the authenticity of the originals of such latter
documents.

         Based upon the foregoing, and subject to the qualifications and
limitations stated herein, we are of the opinion that the shares of Preferred
Stock are legally issued, fully paid and non-assessable shares of the Company
and the holders and owners thereof are entitled to all the rights and
preferences set forth in the Charter.

         We are members of the State Bar of Alabama and we do not express any
opinion herein concerning any law other than the law of the State of Alabama and
the federal law of the United States.

         We hereby consent to the filing of this opinion with the Commission as
an exhibit to the Registration Statement and to the statements with respect to
our name under the heading "Legal Matters" in the prospectus forming part of the
Registration Statement. In giving the foregoing consent, we do not hereby 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 Commission thereunder.
This opinion may not be furnished or quoted to, or relied upon by, any other
person for any purpose, without our prior written consent.

                                                              Very truly yours,