Health literacy, conceptualized as a framework involving basic (functional), interactive and critical skill sets, is a key determinant of health. Application of the health literacy framework (HLF) to immigrant populations has been limited. Our objective was to apply the HLF to discourses about diet-related colon cancer prevention among English-as-a-Second-Language (ESL) immigrant women. We also explored whether these discussions could inform the development of culturally appropriate information and potentially increase health literacy. Interviews were conducted with 64 older Spanish-speaking ESL immigrant women. Directed content analysis guided by the HLF was used to identify themes. Diet-related conversations were initiated by 43 (67%) participants. Four themes were identified: general information requests—low functional health literacy (FHL) (n = 23/43), specific nutrition inquiries—high FHL (n = 17/43), actions for healthy eating—low interactive health literacy (IHL) (n = 8/43) and community communication issues—high IHL (n = 3/43). No conversations representing critical health literacy were identified. Five women discussed both FHL and IHL themes. Women's diet-related conversations followed a continuum of increasing information needs supporting the HLF.