Exhibit 8.1



                               January 2, 2002




Direct Dial                                                           Client No.
(214) 698-3100                                                     C 39334-00015


D.R. Horton, Inc.
1901 Ascension Blvd., Suite 100
Arlington, Texas 76006

         Re:      Acquisition of Schuler Homes, Inc.

Ladies and Gentlemen:

         You have requested our opinion regarding certain federal income tax
consequences of the proposed merger (the "Merger") of Schuler Homes, Inc., a
Delaware corporation ("Schuler"), with and into D.R. Horton, Inc., a Delaware
corporation ("DHI").

         In formulating our opinion, we have reviewed such documents as we
deemed necessary or appropriate, including the Agreement and Plan of Merger,
dated as of October 22, 2001, by and between DHI and Schuler, as amended as of
November 8, 2001 (the "Merger Agreement"), and the Joint Proxy
Statement/Prospectus of DHI and Schuler that is included in the Registration
Statement on Form S-4, as filed with the U.S. Securities and Exchange Commission
on January 2, 2002 (the "Prospectus").

         Our opinion set forth below assumes (i) the accuracy of the statements
and facts concerning the Merger set forth in the Merger Agreement and the
Prospectus; (ii) that the Merger will be consummated in the manner contemplated
by, and in accordance with, the terms set forth in the Merger Agreement and the
Prospectus; and (iii) the accuracy of (a) the representations made to us by DHI,
which are set forth in a Certificate dated January 2, 2002, and (b) the
representations made to us by Schuler, which are set forth in a Certificate
dated January 2, 2002.






D.R. Horton, Inc.
January 2, 2002
Page 2


         Based upon the foregoing and in reliance thereon, and subject to the
qualifications, exceptions, assumptions and limitations herein contained, we are
of the opinion that:

         1.       The Merger will be treated for U.S. federal income tax
                  purposes as a reorganization within the meaning of Section
                  368(a) of the Internal Revenue Code of 1986, as amended (the
                  "Code").

         2.       DHI and Schuler will each be treated as a party to the
                  reorganization within the meaning of Section 368(b) of the
                  Code.

Furthermore, the discussion under the caption "United States Federal Income Tax
Consequences of the Merger" in the Prospectus accurately describes the foregoing
opinion and the material federal income tax consequences of the Merger. We
express no opinion concerning any tax consequences of the Merger other than
those specifically set forth or referred to herein.

         Our opinion is based on current provisions of the Code, Treasury
Regulations promulgated thereunder, published pronouncements of the Internal
Revenue Service, and case law, any of which may be changed at any time with
retroactive effect. Any change in applicable law or the facts and circumstances
surrounding the Merger, or any inaccuracy in the statements, facts, assumptions,
and representations on which we relied, may affect the continuing validity of
the opinion set forth herein. We assume no responsibility to inform you of any
such changes or inaccuracy that may occur or come to our attention.

         This opinion has been furnished to you solely in connection with the
transactions described herein and may not be relied upon by any other person or
by you for any other purpose without our specific, prior, written consent. We
hereby consent to the filing of this opinion as an exhibit to the Registration
Statement, to references to this opinion in the Registration Statement, and to
the use of our name under the caption "United States Federal Income Tax
Consequences of the Merger." In giving this consent, we do not admit that we are
included in the category of persons whose consent is required under Section 7 of
the Securities Act of 1933, as amended, or the rules and regulations promulgated
thereunder.

                                            Very truly yours,



                                            GIBSON, DUNN & CRUTCHER LLP

JMT/DWM/RJB