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                                                                     EXHIBIT 5.1

            [LETTERHEAD OF FRIED, FRANK, HARRIS, SHRIVER & JACOBSON]

                                                             Phone: 212-859-8000

April 26, 2001                                                 Fax: 212-859-4000

Dal-Tile International Inc.
7834 C.F. Hawn Freeway
Dallas, Texas 75217

Ladies and Gentlemen:


    We have acted as special counsel for Dal-Tile International Inc., a Delaware
corporation (the "Company"), in connection with the underwritten public offering
of up to 16,100,000 shares (the "Shares") of common stock, par value $.01 per
share, of the Company by the Selling Stockholders in the Prospectus forming part
of the Registration Statement (File No. 333-59190) filed by the Company with the
Securities and Exchange Commission (the "Registration Statement"). With your
permission, all assumptions and statements of reliance herein have been made
without any independent investigation or verification on our part except to the
extent otherwise expressly stated, and we express no opinion with respect to the
subject matter or accuracy of such assumptions or items relied upon.


    In connection with this opinion, we have (i) investigated such questions of
law, (ii) examined originals or certified, conformed or reproduction copies of
such agreements, instruments, documents and records of the Company, such
certificates of public officials and such other documents, and (iii) received
such information from officers and representatives of the Company as we have
deemed necessary or appropriate for the purposes of this opinion. In all
examinations, we have assumed the legal capacity of all natural persons
executing documents, the genuineness of all signatures, the authenticity of
original and certified documents and the conformity to original or certified
copies of all copies submitted to us as conformed or reproduction copies. As to
various questions of fact relevant to the opinions expressed herein, we have
relied upon, and assume the accuracy of, representations and warranties
contained in the documents and certificates and oral or written statements and
other information of or from representatives of the Company and others and
assume compliance on the part of all parties to the documents with their
covenants and agreements contained therein.

    Based upon the foregoing and subject to the limitations, qualifications and
assumptions set forth herein, we are of the opinion that the Shares are duly
authorized, validly issued, fully paid and non-assessable.

    The opinion expressed herein is limited to the General Corporation Law of
the State of Delaware, as currently in effect.

    We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to this firm under the caption
"Legal Matters" in the Prospectus forming part of the Registration Statement. In
giving such consent, we do not hereby admit that we are in the category of such
persons whose consent is required under Section 7 of the Securities Act of 1933,
as amended.

                                          Very truly yours,

                                          FRIED, FRANK, HARRIS, SHRIVER &
                                          JACOBSON
