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This study analyzes how five major California school districts—Los Angeles, San Francisco, San Diego, Oakland, and Fresno—are developing policies to govern the use of generative AI tools like ChatGPT in K–12 education. Using a qualitative policy-as-discourse framework and Biesta’s educational functions model, we examine district documents to understand how AI is framed, how responsibility is assigned, and what governance mechanisms are enacted. Findings reveal a shift from restrictive bans to more pedagogically supportive approaches, with significant variation in teacher roles, risk management, and policy maturity. By comparing district-level responses, this study highlights how local governance cultures shape the implementation of emerging technologies in schools, offering practical insights for education leaders navigating AI integration.