EXHIBIT 5

Exhibit 5

SOUTHWEST AIRLINES CO.

Deborah Ackerman
Vice President - General Counsel

P.O. Box 36611
Dallas, Texas 75235-1611
(214) 792-4000
Facsimile: (214) 792-6200








July 30, 2004



Southwest Airlines Co.
P.O. Box 36611
Dallas, TX 75235

Dear Sirs:

I have represented Southwest Airlines Co., a Texas corporation (the
"Company"), in connection with the registration with the Securities and
Exchange Commission under the Securities Act of 1933 of the shares of the
common stock, $1 par value of the Company ("Common Stock") to be issued by
the Company from time to time upon the exercise of stock options pursuant to
the Southwest Airlines Co. 2003 Non-Qualified Stock Option Plan (the "Plan").

In this connection, I have examined originals, or copies certified or
otherwise identified to my satisfaction, of such documents, corporate and
other records, certificates and other papers as I deemed it necessary to
examine for the purpose of this opinion, including the Registration Statement
of the Company for the registration of the Common Stock to be issued pursuant
to the Plan on Form S-8 under the Securities Act of 1933 (the "Registration
Statement").

Based on such examination, it is my opinion that the shares of Common
Stock registered under the Registration Statement when issued pursuant to the
terms of the Plan will, upon the payment of the consideration therefor
required by the terms of the Plan, be validly issued, fully paid and non-
assessable.

I consent to the use of this opinion as an exhibit to the Registration
Statement. In giving this consent, I do not thereby admit that I am within
the category of persons whose consent is required under Section 7 of the
Securities Act of 1933, as amended, or the rules and regulation thereunder.


Sincerely,

/s/ Deborah Ackerman

Deborah Ackerman

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