Form: S-8

Initial registration statement for securities to be offered to employees pursuant to employee benefit plans

March 23, 2001

OPINION/CONSENT OF DEBORAH ACKERMAN

Published on March 23, 2001


EXHIBIT 5

SOUTHWEST AIRLINES CO.

Deborah Ackerman
Associate General Counsel

P.O. Box 36611
Dallas, Texas 75235-1611
(214) 792-4665
Facsimile: (214) 792-6200




March 23, 2001


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
pursuant to the Southwest Airlines Co. 2000 Holiday Perfect Attendance Challenge
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 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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