EXHIBIT 5.1



HAMILTON, LEHRER & DARGAN, P.A.
2 EAST CAMINO REAL, SUITE 202
BOCA RATON, FLORIDA 33432
561-416-8956

November 12, 2003

Board of Directors
Atlas Minerals, Inc.
Suite 204, 10920 West Alameda Avenue,
Lakewood, Co  80226

          Re: Atlas Minerals, Inc. Registration Statement on Form S-8 (the
              "Registration Statement")

Ladies and Gentlemen:

We have acted as special counsel to Atlas Minerals, Inc., a Colorado
corporation, (the "Company") in connection with the issuance of 800,000 shares
of the Company's common stock, (the "Shares"), pursuant to the terms and
conditions described in the Company's Registration Statement on Form S-8 dated
November 12, 2003.

You have advised us that:

1. The Company is current in its reporting responsibilities to the Securities
and Exchange Commission as mandated by the Securities Exchange Act of 1934, as
amended.

2. The Shares will be issued to consultants and participants in the 2003
Consultant Stock Grant Plan as compensation for their services on behalf of the
Company. Such persons have provided bona-fide services to the Company which are
not in relation to the offer or sale of securities in a capital-raising
transaction, and which did not either directly or indirectly promote or maintain
a market for the Company's securities.

3. The Shares to be issued to these individuals are pursuant to corporate
resolution and the approval of the Board of Directors of the Company.

In connection with the representation, I have examined such records and
documents and made such examinations of law as I have deemed relevant in
connection with this opinion. In my examination, I 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 certified or photostatic copies and the
authenticity of the originals of such copies.

Based on the accuracy of the information supplied to me, subject to the
limitation set forth in the Company's Articles of Incorporation with respect to
the maximum number of shares of common stock that the Company is authorized to
issue, and assuming that the Shares will be issued as set forth in the
Registration Statement, at a time when effective, and that the Company will
fully comply with all applicable securities laws involved under the Securities
Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, and
the rules and regulation promulgated pursuant to these Acts, and in those states
of foreign jurisdictions in which the Shares may be sold, we are of the opinion
that, upon proper and legal issuance of the Shares and receipt of the
consideration to be paid for the Shares, the Shares will be duly authorized,
validly issued, fully paid and nonassessable shares of common stock of Atlas
Minerals, Inc.


This opinion does not cover any matters related to any re-offer or re-sale of
the Shares by any Plan participants, once properly and legally issued as
described in and pursuant to the Registration Statement.

I hereby consent to the filing of this opinion with the Securities and Exchange
Commission as Exhibit 5.0 to the Registration Statement. I also consent to the
reference to my firm under the heading in the Registration Statement. In giving
this consent, I do not thereby admit that I am in 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.

This opinion is limited to the specific issues addressed herein, and no opinion
may be inferred or implied beyond that expressly stated herein. I assume no
obligation to revise or supplement this opinion should the present applicable
laws be changed by legislative action, judicial decision or otherwise.

Very truly yours,

/s/ Hamilton, Lehrer and Dargan P.A.
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    Hamilton, Lehrer and Dargan P.A.