This policy analysis, informed by ethnographic techniques, reviewed 12 Florida school district ESOL policies. A priori coding of these policies was conducted using criteria pulled from the literature on culturally responsive practice (CRP). Subsequent observations and practitioner interviews within two schools from the same district were conducted in order to ascertain on an initial, exploratory level how practice aligned with policy, how these practices differed from site to site, and ultimately to assess the efficacy of observed pedagogical and administrative practices within the theoretical framework of CRP and their potential effects on minority student populations and their families. Results were worrying and indicated little comprehensive coverage of CRP in any one given policy document, a lack of teacher awareness of policy stipulations, and scarce professional development (PD) relative to CRP. Multiple other important findings are also discussed with implications for ESOL policymakers and practitioners in the United States and abroad.