EXHIBIT 5.1


                                 April 17, 2002


Ladies and Gentlemen:

      I am the General Counsel of DaVita Inc., a Delaware corporation (the
"Company") and the holder of stock and options to purchase stock granted under
the Company's employee stock plans which in the aggregate represent less than 1%
of the Company's outstanding Common Stock. I am delivering this opinion in
connection with the registration under the Securities Act of 1933, as amended
(the "1933 Act"), of up to 8,500,000 shares of the Common Stock, $0.001 par
value per share (the "Shares") issuable upon the exercise of options granted
under the DaVita Inc. 2002 Equity Compensation Plan (the "Plan"). This opinion
is delivered in connection with that certain Registration Statement on Form S-8
(the "Registration Statement") to be filed with the Securities and Exchange
Commission (the "Commission") under the 1933 Act to register the Shares.

      In rendering the opinion set forth herein, I have made such investigations
of fact and law, and examined such documents and instruments, or copies thereof
established to my satisfaction to be true and correct copies thereof, as I have
deemed necessary under the circumstances.

      Based upon the foregoing and such other examination of law and fact as I
have deemed necessary, and in reliance thereon, I am of the opinion that the
Shares, when offered, sold and paid for pursuant to the exercise of options
granted under the Plan, will be duly authorized, validly issued, fully paid and
non-assessable.

      I hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to me under the caption "Interests
of Named Experts and Counsel" in Item 5 of Part II of the Registration
Statement. In giving such consent, I do not thereby admit that I am in the
category of persons whose consent is required under Section 7 of the 1933 Act or
the rules and regulations of the Commission thereunder.

                                Very truly yours,

                                /s/ Steven J. Udicious