Riversource of New York Variable Annuity Account 1, et al. – ‘485BPOS’ on 9/30/05 – EX-99.9 OPIN COUNSEL

On:  Friday, 9/30/05, at 3:08pm ET   ·   Effective:  10/3/05   ·   Accession #:  820027-5-835   ·   File #s:  333-00041, 811-07475

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Post-Effective Amendment
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 485BPOS     Acl Variable Annuity Account 1                        15    108K 
 2: EX-99       Exhibit Index                                          1      4K 
 4: EX-99.10 AUD CONSENT  Consent of Independent Registered Public     1      6K 
                          Accounting Firm                                        
 3: EX-99.9 OPIN COUNSEL  Opinion of Counsel and Consent               1      8K 

EX-99.9 OPIN COUNSEL   —   Opinion of Counsel and Consent

September 30, 2005                                                              

American Centurion Life Assurance Company                                       
20 Madison Avenue Extension                                                     
Albany, NY  12203                                                               

RE:     ACL Variable Annuity Account 1                                          
Post-Effecitve Amendment No. 11                                 
File No. 333-00041/811-07475                                    

I am familiar  with the  establishment  of the ACL  Variable  Annuity  Account 1
("Account"),  which is a separate  account of American  Centurion Life Assurance
Company ("Company") established by the Company's Board of Directors according to
applicable   insurance  law.  I  also  am  familiar  with  the  above-referenced
Registration  Statement  filed by the Company on behalf of the Account  with the
Securities and Exchange Commission.                                             

I have made such  examination  of law and examined such documents and records as
in my judgment are necessary and  appropriate to enable me to give the following
opinion:                                                                        

1.   The Company is duly  incorporated,  validly  existing and in good  standing
     under applicable state law and is duly licensed or qualified to do business
     in each  jurisdiction  where it  transacts  business.  The  Company has all
     corporate  powers  required  to carry  on its  business  and to  issue  the
contracts.                                                            

2.   The  Account is a validly  created  and  existing  separate  account of the
Company and is duly authorized to issue the securities registered.    

3.   The  contracts  issued by the Company,  when offered and sold in accordance
     with  the  prospectus  contained  in  the  Registration  Statement  and  in
     compliance  with  applicable  law,  will be legally  issued  and  represent
binding obligations of the Company in accordance with their terms.    

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.                                                                      

Sincerely,                                                                      

/s/ Mary Ellyn Minenko                                                          
----------------------                                                          
Mary Ellyn Minenko                                                      
Counsel                                                                 

Dates Referenced Herein

This ‘485BPOS’ Filing		Date		Other Filings
Effective on:		10/3/05		None on these Dates
Filed on:		9/30/05
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