Exhibit 8.1

                                                     King & Spalding LLP
                                                     191 Peachtree Street
                                                     Atlanta, Georgia 30303-1763
                                                     Main: 404/572-4600
                                                     Fax: 404/572-5100

                                 March 5, 2003

SunTrust Banks, Inc.
303 Peachtree Street, N.E.
Atlanta, Georgia  30308

         Re:      Federal Income Tax Consequences of Merger of Lighthouse
                  Financial Services, Inc. with and into SunTrust Bank Holding
                  Company, a Wholly Owned Subsidiary of SunTrust Banks, Inc.

Ladies and Gentlemen:

         We have acted as counsel to SunTrust Banks, Inc., a Georgia corporation
("SunTrust"), in connection with the Agreement and Plan of Merger and
Reorganization dated as of January 21, 2003 (the "Merger Agreement"), among
Lighthouse Financial Services, Inc., a Delaware corporation ("Lighthouse"),
SunTrust, and SunTrust Bank Holding Company, a Florida corporation and wholly
owned subsidiary of SunTrust ("Holdings"), pursuant to which Lighthouse shall be
merged with and into Holdings with Holdings surviving as a wholly owned
subsidiary of SunTrust (the "Merger") on the terms and conditions set forth
therein.

         We understand that this opinion will appear as Exhibit 8.1 to the
Registration Statement on Form S-4 (the "Registration Statement") filed by
SunTrust with the Securities and Exchange Commission under the Securities Act of
1933, as amended, relating to the proposed Merger pursuant to the Merger
Agreement. We hereby consent to such use of our opinion.

         For purposes of this opinion, capitalized terms used and not otherwise
defined herein shall have the meanings ascribed thereto in the Merger Agreement.
The time at which the Merger becomes effective is hereafter referred to as the
"Effective Time."

                              INFORMATION RELIED ON

         In rendering the opinion expressed herein, we have examined such
documents as we have deemed appropriate, including (i) the Merger Agreement,
(ii) the Registration Statement, and (iii) the representation letters of
Lighthouse and SunTrust delivered to us for purposes of this opinion (the
"Representation Letters"). In addition, we have examined, and have relied as to
matters of fact upon, originals or copies, certified or otherwise identified to
our satisfaction, of such corporate records, agreements, documents, and other
instruments and have made such other inquiries as we have deemed necessary or
appropriate to enable us



SunTrust Banks, Inc.
March 5, 2003
Page 2

to render the opinion set forth below. In such examination, 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. We have not, however, undertaken any independent investigation of any
factual matter set forth in any of the foregoing.

         In rendering our opinion, we have assumed, with your permission, that
(i) the Merger will be effected in accordance with the Merger Agreement, (ii)
the statements concerning the Merger set forth in the Merger Agreement and the
Registration Statement are accurate and complete and will remain accurate and
complete at all times up to and including the Effective Time, (iii) the
representations made by Lighthouse and SunTrust in the Representation Letters
are and will remain accurate and complete at all times up to and including the
Effective Time, and (iv) any representations made in the Merger Agreement or the
Representation Letters "to the knowledge of," or based on the belief of,
Lighthouse or SunTrust or similarly qualified are accurate and complete and will
remain accurate and complete at all times up to and including the Effective
Time, in each case without such qualification. We also have assumed that the
parties have complied with and, if applicable, will continue to comply with, the
covenants contained in the Merger Agreement.

                                     OPINION

         Based upon the foregoing, we hereby confirm our opinion set forth in
the discussion contained in the Registration Statement under the caption
"Material United States Federal Income Tax Consequences."

         The opinion expressed herein is based upon existing statutory,
regulatory, and judicial authority, any of which may be changed at any time with
retroactive effect. In addition, our opinion is based solely on the documents
that we have examined, the additional information that we have obtained, and the
statements of fact set out herein that we have assumed, with your consent, to be
accurate and complete. Our opinion cannot be relied upon if any of the facts
contained in such documents or in any such additional information is, or later
becomes, inaccurate or if any of the assumed facts set out herein is, or later
becomes, inaccurate. Finally, our opinion is limited to the tax matters
specifically covered thereby, and we have not been asked to address, nor have we
addressed, any other tax consequences of the Merger.


                                       Very truly yours,



                                       /s/ King & Spalding