EXHIBIT 5.1

May 14, 1999

Armstrong World Industries, Inc.
2500 Columbia Avenue
Lancaster, Pennsylvania  17603

Re:  Armstrong World Industries, Inc.
     Registration Statement on Form S-3 (File No. 333-74501)
     -------------------------------------------------------

Ladies and Gentlemen:

We have acted as special New York counsel to Armstrong World Industries, Inc., a
Pennsylvania corporation (the "Company"), in connection with the issuance and
sale by the Company to the Underwriters (as defined below) of $200,000,000
aggregate principal amount of the Company's 7.45% Senior Notes due 2029 (the
"Senior Notes").  The offering of the Senior Notes is being made pursuant to the
Company's Registration Statement on Form S-3 (including a prospectus supplement
filed pursuant to Rule 424 of the Securities Act of 1933, as amended, the
"Registration Statement") which relates to the offer and sale by the Company
from time to time of up to $1,000,000,000 aggregate principal amount of debt
securities, common stock, $1.00 par value per share, shares of Class A preferred
stock, no par value per share, warrants and depositary shares.

The Senior Notes are being sold pursuant to that certain Underwriting Agreement
(the "Underwriting Agreement"), dated May 14, 1999, by and among Salomon Smith
Barney Inc., J.P. Morgan Securities Inc., Banc One Capital Markets, Inc.,
Barclays Capital Inc. and HSBC Securities, Inc. (collectively, the
"Underwriters"), and the Company. The Underwriting Agreement incorporates the
terms and conditions of the "Underwriting Agreement Standard Provisions - Debt
Securities and Preferred Stock," and relates to the purchase by the
Underwriters, severally and not jointly, from the Company of the Senior Notes.
It is contemplated that the Senior Notes will be issued pursuant to an indenture
(the "Indenture"), dated December 23, 1998, between the Company and The First
National Bank of Chicago, as trustee.

We have examined such documents, records, and matters of law as we have deemed
necessary for purposes of this opinion.  In examining all such documents, we
have assumed the genuineness of all signatures, the authenticity of all
documents purporting to be originals, and the conformity to the respective
originals of all documents purported to be copies.  In rendering the foregoing
opinions, we have relied as to certain factual matters upon certificates of
officers of the Company, and we have not independently verified the accuracy of
the statements contained therein.

Based on and subject to the foregoing and such examination of law as we have
deemed necessary, we are of the opinion that the Senior Notes have been duly
authorized by the Company and, when executed, authenticated, issued and
delivered in the manner provided in the Indenture against payment of the
consideration therefor specified in the Underwriting Agreement, will be entitled
to the benefits of the Indenture, and will be valid and legally binding
obligations of the Company, enforceable in accordance with their terms, except
as enforceability may be limited by bankruptcy, reorganization, moratorium,
insolvency or similar laws affecting creditors' rights generally, including
without limitation, applicable fraudulent transfer laws, and general principles
of equity, including without limitation, concepts of


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Page 2


materiality, reasonableness, good faith and fair dealing (regardless of whether
the enforceability of such rights or the availability of such remedies is
considered in a proceeding in equity or at law).

The opinion set forth in this letter relates only to the federal laws of the
United States of America and the laws of the State of New York.  As to matters
of Pennsylvania law relevant to the opinions set forth above, we have relied on
the opinion of Douglas S. Brossman, Senior Attorney of the Company, dated the
date hereof, a copy of which is filed as Exhibit 5.2 to the Company's Current
Report on Form 8-K, dated May 14, 1999 (the "Form 8-K").

We assume no obligation to advise you of any changes in the foregoing subsequent
to the delivery of this opinion.  This opinion has been prepared solely for your
use in connection with the filing of the Form 8-K incorporated by reference into
the Registration Statement, and should not be quoted in whole or in part or
otherwise be referred to, nor otherwise be filed with or furnished to any
governmental agency or other person or entity, without our express prior written
consent.

We hereby consent to the filing of this opinion as an exhibit to the Form 8-K
and to the use of our name in the Registration Statement under the caption
"Legal Matters."  In giving this consent, we do not admit that we are within the
category of persons whose consent is required under Section 7 of the Securities
Act of 1933, as amended, or the rules and regulations of the Securities and
Exchange Commission promulgated thereunder.

Very truly yours,


/s/ Rogers & Wells LLP