Exhibit 5

                    [COOPER TIRE & RUBBER COMPANY LETTERHEAD]

                                  March 5, 2004

Securities and Exchange Commission
Judiciary Plaza
450 5th Street
Washington, DC 20549

                           Re: Pre-Tax Savings Plan At The Auburn Plant
                               Pre-Tax Savings Plan (Bowling Green-Hose)
                               Pre-Tax Savings Plan (Bowling Green-Sealing)
                               Pre-Tax Savings Plan (Clarksdale)
                               Pre-Tax Savings Plan At The El Dorado Plant
                               Pre-Tax Savings Plan At The Findlay Plant
                               Texarkana Pre-Tax Savings Plan

Ladies and Gentlemen:

         I have acted as counsel for Cooper Tire & Rubber Company, a Delaware
corporation ("Registrant"), in connection with the plans listed above ("Plans").
I have examined such documents, records and matters of law as I have deemed
necessary for purposes of this opinion, and based thereupon, I am of the opinion
that:

         1.       The Registrant's shares of Common Stock, par value $1 per
                  share ("Common Stock"), that may be issued or transferred and
                  sold pursuant to the Plans will be, when issued or transferred
                  and sold in accordance with the Plans, duly authorized,
                  validly issued, fully paid and nonassessable.

         2.       When issued in accordance with the Rights Agreement dated as
                  of May 1, 1998 between Registrant and Fifth Third Bank, as
                  Rights Agent ("Rights Agreement"), the Series A Preferred
                  Stock Purchase Rights ("Rights") will be validly issued.

         The opinion set forth in paragraph 2 is limited to the valid issuance
of the Rights under the corporation laws of the State of Delaware. I do not
express any opinion herein with respect to any other aspect of the Rights, the
effect of equitable principles or fiduciary considerations relating to the
adoption of the Rights Agreement or the issuance of the Rights or the
enforceability of any particular provisions of the Rights Agreement.

         I hereby consent to the filing of this opinion as Exhibit 5 to the
Registration Statement on Form S-8 filed by the Registrant to effect
registration of the Common Stock to be issued and sold pursuant to the Plan
under the Securities Act of 1933.

                                        Very truly yours,

                                        /s/ James E. Kline
                                            ------------------------------------
                                            James E. Kline