Four Corners Property Trust, Inc., a Maryland corporation (the “Company”) – Registration of shares of common stock, $0.0001 par value per share (the “Common Stock”), of the Company having an aggregate gross sales price of up to $450,000,000 (the “Shares”) to be sold in an at-the-market offering (the “Offering”) pursuant to a Registration Statement on Form S-3 (File No. 333-268205) filed with the Securities and Exchange Commission (the “Commission”) on November 7, 2022 (the “Registration Statement”)

the corporate charter of the Company (the “Charter”) represented by Articles of Amendment and Restatement filed with the State Department of Assessments and Taxation of Maryland (the “Department”) on October 22, 2015;

the Amended and Restated Bylaws of the Company, dated as of October 22, 2015 (the “Bylaws”);

resolutions adopted, and other actions taken, by the Board of Directors of the Company (the “Board”) on or as of September 15, 2022 (the “Board Resolutions”), resolutions adopted by the Pricing Committee of the Board (the “Pricing Committee”) on or as of November 7, 2022 (the “Pricing Committee Resolutions”), and the form of resolutions, in substantially the form attached to the Agreement (as defined herein) as Exhibit A, to be adopted from time to time by the Pricing Committee (the “Subsequent Pricing Committee Resolutions”, and together with the Board Resolutions and the Pricing Committee Resolutions and any additional resolutions adopted, or other actions taken, subsequent to the date hereof by the Board as contemplated by paragraph (j) below, collectively, the “Directors’ Resolutions”);

the Registration Statement filed by the Company with the Commission under the Act, the related base prospectus, dated November 7, 2022, and the related prospectus supplement, dated November 7, 2022;

a fully executed counterpart of the Equity Distribution Agreement, dated as of November 7, 2022 (the “Agreement”), by and among the Company, Four Corners Operating Partnership, LP, a Delaware limited partnership, of which the sole general partner is Four Corners GP, LLC, a Delaware limited liability company and a wholly owned subsidiary of the Company, and Morgan Stanley & Co. LLC, Barclays Capital Inc., BofA Securities, Inc., Evercore Group L.L.C., Goldman Sachs & Co. LLC, J.P. Morgan Securities LLC, Mizuho Securities USA LLC, Raymond James & Associates, Inc., Robert W. Baird & Co. Incorporated, Truist Securities, Inc. and Wells Fargo Securities, LLC, each as sales agent, principal and, if applicable, forward seller (in any such capacity, each, a “Manager”, and collectively, the “Managers”), and Morgan Stanley & Co. LLC, Bank of America, N.A., Barclays Bank PLC, Goldman Sachs & Co. LLC, JPMorgan Chase Bank, National Association, Mizuho Markets Americas LLC, Raymond James & Associates, Inc., Truist Bank and Wells Fargo Bank, National Association, each as forward purchaser;

a status certificate of the Department, dated as of a recent date, to the effect that the Company is duly incorporated and existing under the laws of the State of Maryland;

a certificate of one or more officers of the Company, dated as of a recent date (the “Officers’ Certificate”), to the effect that, among other things, the Charter, the Bylaws, the Board Resolutions and the Pricing Committee Resolutions are true, correct and complete and have not been rescinded or modified and are in full force and effect on the date of the Officers’ Certificate, and certifying as to the manner of adoption of the Board Resolutions and the Pricing Committee Resolutions, the authorization for issuance of the Shares, the form of the Subsequent Pricing Committee Resolutions and the form, approval, execution and delivery of the Agreement; and

such other documents and matters as we have deemed necessary and appropriate to render the opinions set forth in this letter, subject to the limitations, assumptions, and qualifications noted below.

each person executing any of the Documents on behalf of any party (other than the Company) is duly authorized to do so;

each natural person executing any of the Documents is legally competent to do so;

any of the Documents submitted to us as originals are authentic; the form and content of any Documents submitted to us as unexecuted drafts do not, and will not, differ in any respect relevant to this opinion from the form and content of such documents as executed and delivered; any of the Documents submitted to us as certified, facsimile or photostatic copies conform to the original document; all signatures on all of the Documents are genuine; all public records reviewed or relied upon by us or on our behalf are true and complete; there has been no modification of, or amendment to, any of the Documents, and there has been no waiver of any provision of any of the Documents by action or omission of the parties or otherwise;

the Officers’ Certificate and all other certificates submitted to us are true and correct both when made and as of the date hereof;

neither the issuance and sale of the Shares pursuant to the Agreement, nor the ownership of the Shares by purchasers thereof, will violate any of the ownership or transfer restrictions or limitations contained in the Charter;

prior to the issuance and sale of any of the Shares, the Subsequent Pricing Committee Resolutions setting forth, with respect to such Shares, the maximum number of Shares to be issued and sold, the minimum price to be received by the Company per Share (after giving effect to any discounts provided or commissions paid by the Company in connection with the offering of such Shares), and the maximum compensation to be paid to the Managers, will have been duly adopted at a duly convened meeting of the members of the Pricing Committee, or by unanimous consent of the members of the Pricing Committee given in writing or by electronic transmission, in accordance with the powers and authority delegated to the Pricing Committee by the Board pursuant to the Board Resolutions;

the aggregate gross sales price of all of the Shares sold pursuant to the Agreement will not exceed $450,000,000, and the aggregate number of Shares issued and sold pursuant to the Agreement will not exceed the maximum aggregate number authorized for issuance and sale in the Directors’ Resolutions;

the consideration per share to be received by the Company for each Share issued and sold pursuant to the Agreement will be determined in accordance with, and will not be less than the minimum consideration per share set forth in, the Directors’ Resolutions;

upon each issuance of any of the Shares subsequent to the date hereof, the total number of shares of Common Stock of the Company issued and outstanding, after giving effect to such issuance of such Shares, will not exceed the total number of shares of Common Stock that the Company is authorized to issue under the Charter; and

to the extent that Shares are issued and sold on or after the date hereof pursuant to the Agreement (any Shares so issued and sold on or after such date, the “Additional Shares”), the Board will have taken valid action in accordance with Maryland law prior to the issuance and sale of any such Additional Shares to

The Company has been duly incorporated and is validly existing as a corporation in good standing under the laws of the State of Maryland.

The Shares to be issued in the Offering have been generally authorized for issuance by the Company pursuant to the Agreement, and when such Shares are issued and delivered pursuant to due authorization by the Board or the Pricing Committee subsequent to the date hereof, in exchange for payment of the consideration therefor, as provided in, and in accordance with the terms of, the Agreement and the Directors’ Resolutions, such Shares will be duly authorized, validly issued, fully paid and nonassessable.