OPINION/CONSENT OF DEBORAH ACKERMAN

EXHIBIT 5.2


SOUTHWEST AIRLINES CO.

Deborah Ackerman
Vice President - General Counsel

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





October 10, 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 proposed offering, issuance and sale of up to
$1,000,000,000 principal amount of Debt Securities (the "Securities") to be
issued from time to time under a Trust Indenture (the "Indenture") between the
Company and U.S. Trust Company of Texas, N.A., as Trustee (the "Trustee"), such
Securities to bear interest at such rates and to be payable at such times, to
mature at such times and otherwise to have such terms as contemplated by the
Prospectus included as part of the Registration Statement on Form S-3 (the
"Registration Statement") with respect to the Securities which is being filed
with the Securities and Exchange Commission under the Securities Act of 1933 and
Rule 415 thereunder.

For the purposes of this opinion, I have examined such corporate records
and other documents and have reviewed such questions of law as I considered
necessary or appropriate for the purposes of this opinion.

Based on such examination and review, I hereby advise you that, in my
opinion, the execution and delivery by the Company of the Indenture has been
duly authorized by the Company. Further, when the Registration Statement has
become effective under the Securities Act of 1933, and all necessary proceedings
have been taken by the Board of Directors or the Executive Committee of such
Board of Directors of the Company in connection with the authorization, issuance
and sale of the Securities of a particular series and related matters, the
Securities, when duly executed on behalf of the Company and authenticated by the
Trustee and issued and delivered pursuant to the Indenture against payment to
the Company of the authorized consideration therefor, will be duly authorized
and validly issued and constitute binding obligations of the Company except as
may be limited by (a) applicable bankruptcy, insolvency, moratorium,
reorganization or other similar laws affecting enforcement of creditors' rights
generally and (b) general principles of equity (regardless of whether such
enforceability is considered in a proceeding at law or in equity).

I hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to me under the caption "Legal
Opinions" in the Prospectus relating to the Securities
Southwest Airlines Co.
October 10, 2001
Page 2


forming a part of 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 and the rules and regulations of
the Securities and Exchange Commission thereunder.

Sincerely,

/s/ Deborah Ackerman

Deborah Ackerman

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