Exhibit 5.1

                         Law Office of Kevin M. Sherlock
                          2920 N. Swan Road, Suite 206
                                Tucson, AZ 85712
                                  520 906-3567

                                 October 11, 2004

Southwest Olive Growers, Inc.
11053 Lopez Ridge Way
San Diego, CA 92121

         Re: Registration Statement on
         Form SB-2 (the "Registration Statement")

Gentlemen:

     You have  requested  my opinion as to the  legality of the  issuance by you
(the "Corporation") of 200,000 shares of common stock ("Shares"), all as further
described  in the  Registration  Statement  filed with the U.S.  Securities  and
Exchange Commission.

     As your counsel, I have reviewed and examined:

         1. The Articles of Incorporation  of the Corporation;  2. The Bylaws of
         the Corporation;  3. A copy of certain  resolutions of the Corporation;
         and 4. The Registration Statement.

         In  giving  my  opinion,  I  have  assumed  without  investigation  the
authenticity of any document or instrument  submitted to me as an original,  the
conformity  to the original of any document or  instrument  submitted to me as a
copy, and the genuineness of all signatures on such originals or copies.

         Based upon the  foregoing,  I am of the opinion that under  Arizona law
including the statutory  provisions,  all  applicable  provisions of the Arizona
constitution and reported judicial decisions interpreting those laws, the Shares
to be offered  pursuant to the Registration  Statement,  if sold as described in
the   Registration   Statement   will  be   legally   issued,   fully  paid  and
non-assessable.  I am also  of the  opinion  that  the  Shares  have  been  duly
authorized by the Board of Directors.

         No  opinion  is  expressed  herein  as  to  the  application  of  state
securities or Blue Sky laws.

         I consent to the reference to my name in the Prospectus filed as a part
of the  Registration  Statement  and the use of my opinion  in the  Registration
Statement.

Very truly yours,

/s/
Kevin M. Sherlock