Exhibit 5.1

[Holland & Hart LLP logo]




                                 August 4, 2009

ENGlobal Corporation
654 N. Sam Houston Parkway E., Suite 400
Houston, TX  77060

     Re: Registration Statement on Form S-8

Ladies and Gentlemen:

     We are acting as special Nevada counsel for ENGlobal Corporation, a Nevada
corporation (the "Company"), in connection with the Registration Statement on
Form S-8 (the "Registration Statement") relating to the registration under the
Securities Act of 1933, as amended (the "Act"), of 433,125 shares of Common
Stock, par value $0.001 per share (the "Common Stock") of the Company reserved
for issuance directly or upon exercise of stock options to be issued under the
Company's 2009 Equity Incentive Plan (the "Plan").

     We have reviewed and are familiar with (a) the Company's Articles of
Incorporation, as amended, and Bylaws, (b) a certificate of an officer of the
Company representing certain matters in connection with the original issuance of
the Common Stock, which representations we have assumed the validity of and
relied on, and (c) such other matters as we have deemed necessary for this
opinion.

     Based upon the foregoing, we are of the opinion that the shares of Common
Stock to be offered and sold by the Company under the Registration Statement,
when issued in accordance with the terms of the Plan and the Registration
Statement, will be duly authorized and legally issued by the Company and fully
paid and nonassessable. This opinion is limited to matters governed by the laws
of the State of Nevada.

     We hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement. In giving this consent, we do not thereby admit that we
are within 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
promulgated thereunder.

                                            Sincerely,

                                            /s/ Holland & Hart LLP






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