The Law Office of James G. Dodrill II, P.A.
                              5800 Hamilton Way
                          Boca Raton, Florida 33496
                             Tel. (561) 862-0529
                             Fax: (561) 862-0927
                          Email: jgd2pa@adelphia.net
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                               June 13, 2005

Cycle Country Accessories Corp.
2188 Highway 86
Milford, Iowa 51351



Gentlemen and Ladies:

     At your request, I have acted as counsel for Cycle Country
Accessories Corp., a Nevada corporation (the "Company"), in
connection with preparation of the Company's Registration
Statement on Form S-3 (the "Registration Statement") under the
Securities Act of 1933, as amended, concerning registration of
2,000,000 shares of the Company's $.0001 par value common stock
(the "Common Stock") to be sold by certain selling shareholders of the
Company, as identified in the Registration Statement.


     In connection with the rendering of this opinion, I have examined
the originals or copies of such documents, corporate records, certificates
of public officials and officers of the Company, and other instruments
related to the authorization and issuance of the Common Stock, as I deemed
relevant or necessary for the opinion expressed herein.  Based upon the
foregoing, it is my opinion that the shares of Common Stock to be sold
by the selling shareholders will, when sold, be legally issued, fully paid,
and non-assessable and that the Company has the power to, and has properly
issued the Common Stock.


     I hereby consent (a) to be named in the "Legal Matters" section of
the Registration Statement and the prospectus that constitutes a part of the
Registration Statement (including any amendments thereto) as acting as
counsel in connection with the offering; and (b) to the filing of this
opinion as an exhibit to the Registration Statement.

     This opinion is to be used solely for the purpose of
the registration of the Common Stock and may not be used for any
other purpose.

                           Sincerely,
                           Law Office of James G. Dodrill II, PA


                            /s/ James G. Dodrill II, Esq.
                           ------------------------------
                           By:  James G. Dodrill II, Esq.