OPINION AND CONSENT OF DEBORAH ACKERMAN

[SOUTHWEST AIRLINES CO. LETTERHEAD]



Exhibit 5







November 19, 1998


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 deferred compensation obligations
(the "Obligations") to be issued by the Company from time to time pursuant to
the Southwest Airlines Co. Excess Benefit 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 Obligations to be issued pursuant to the Plan on
Form S-8 under the Securities Act of 1933 (the "Registration Statement").

I am admitted to the Bar in the State of Texas, and do not express any
opinion as to the laws of any other jurisdiction except for the general
corporate laws of the State of Texas and federal laws.

Based upon and subject to the foregoing, I am of the opinion that (i)
the Plan and the Trust Agreement have been duly and validly approved by the
Company, and (ii) the Deferred Compensation Obligations have been duly and
validly authorized by the Company.

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