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The COVID-19 pandemic presents unprecedented challenges to educational equity for multilingual learners (MLs) and their families. Given that state education agencies set policy and guidance for schools and districts, they are well-positioned to ensure civil rights obligations for MLs are upheld. This paper reports findings from a policy analysis of over 150 state guidance documents, examining the extent to which states address six areas of ML policy, as well as how they characterize MLs. Findings reveal substantial variation in the depth of states’ guidance, which corresponded with whether characterizations of MLs focused on assets or perceived deficits. Implications consider how state leaders can support schools and districts in attending to equity for MLs during and beyond the pandemic.