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                                                                    EXHIBIT 5.2



                              February 24, 1997




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
$100,000,000 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 has been filed
with the Securities and Exchange Commission under the Securities Act of 1993
and Rule 415 thereunder (File No. 33-59113) and which became effective on
May 9, 1995.

        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 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 of such series, 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 will be binding obligations of the
Company.

        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 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
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Southwest Airlines Co.
February 24, 1997

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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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