Exhibit (i)

                                October 31, 2002

Board of Directors
Columbia Special Fund, Inc.
1301 SW Fifth Avenue
PO Box 1350
Portland, OR 97207-1350

      We have acted as counsel to Columbia Special Fund, Inc. (the "Fund") in
connection with the preparation and filing of the Fund's Registration Statement
on Form N-1A (the "Registration Statement") under the Securities Act of 1933,
covering an indefinite number of shares of Common Stock of the Fund (the
"Shares") pursuant to Rule 24f-2. We have reviewed the corporate action of the
Fund in connection with this matter and have examined those documents, corporate
records and other instruments we deemed necessary for purposes of this opinion.

      Based upon the foregoing, it is our opinion that:

      1. The Fund has been duly organized and is validly existing as a
corporation under the laws of the state of Oregon;

      2. One billion shares of the Fund have been duly authorized; and

      3. The Shares, when issued and sold in the manner described in the
Prospectus included in the Registration Statement and in accordance with
resolutions adopted by the Board of Directors of the Fund, and when payment
therefor shall have been received by the Fund, will be legally issued, fully
paid and nonassessable.

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


                                Very truly yours,


                                 STOEL RIVES LLP