EXHIBIT 5.1



                                  March 7, 2007


Perrigo Company
515 Eastern Avenue
Allegan, Michigan  49010

         Re:   Registration Statement on Form S-8

Ladies and Gentlemen:

         I have acted as counsel to Perrigo Company, a Michigan corporation (the
"Company"), in connection with the filing of a Registration Statement on Form
S-8 by the Company under the Securities Act of 1933, as amended (the
"Registration Statement"), which Registration Statement registers 750,000 shares
of Common Stock, without par value (the "Common Stock"), reserved for issuance
under the Company's Profit-Sharing and Investment Plan, as amended (the "Plan").
In that capacity, I have reviewed the Amended and Restated Articles of
Incorporation and Restated Bylaws of the Company, both as amended to date, the
Registration Statement, the Plan, originals or copies of corporate records
reflecting the corporate action taken by the Company in connection with the
approval and amendment of the Plan and the issuance of the Common Stock under
the Plan and such other instruments as I have deemed necessary for the issuance
of this opinion.

         Based upon the foregoing, I am of the opinion that the Common Stock to
be offered under the Plan has been duly authorized by all requisite action on
the part of the Company and, when issued in accordance with the terms and
conditions of the Plan, will be legally issued, fully paid and non-assessable.

         I consent to the filing of this opinion as an exhibit to the
Registration Statement. In giving this consent, I do not admit that I am within
the category of persons whose consent is required by Section 7 of the Securities
Act of 1933, as amended.

                                        Very truly yours,

                                        /s/ Todd W. Kingma

                                        Todd W. Kingma
                                        Executive Vice President, Secretary and
                                        General Counsel