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Artificial intelligence (AI) has the potential to enhance the learning of students with disabilities (SWD), but the implementation requires careful consideration and guidance. This study aims to identify common themes and assess how state AI guidance addresses the needs of SWD by using a thematic analysis. The researchers identified five common themes: (a) benefits and risks, (b) training and support, (c) policy development, (d) ethical use, (e) human-centered AI. In addition, three themes emerged specifically for SWD: (a) accessibility, (b) personalized learning, (c) equity. The findings from this study suggested that although many states support using AI for SWD, it is necessary to provide more concrete guidance for inclusive and equitable access.