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As a federal mechanism for promoting educational equity under the Every Student Succeeds Act (ESSA), subgroup accountability holds states and schools responsible for the comparative performance of specific student groups. States were provided an opportunity to revise their policies around subgroup accountability when submitting their ESSA plans to the US Department of Education for approval. This paper analyzes all approved plans for how states legitimized their policymaking decisions regarding subgroup accountability, focusing on n-size and subgroup composition. By applying categories of discursive legitimation, we show the various strategies employed to justify decisions around educational equity and discuss implications for policymaking.