The COVID-19 pandemic presents unprecedented challenges to educational equity for multilingual learners (MLLs) and their families. Given that state education agencies play a prominent role in guiding and supporting schools and districts, they are well-positioned to ensure civil rights obligations for MLLs are upheld amidst the pandemic. This article reports findings from a policy analysis of over 150 state guidance documents related to the COVID-19 pandemic, collected across 50 states and the District of Columbia. Documents were reviewed to examine the extent to which states addressed key issues pertaining to MLL education, as well as how they characterized MLL students and families. Findings reveal substantial variation in the depth of states' guidance focused on six areas of MLL policy, which corresponded with whether characterizations of MLL students and families focused on their assets or perceived deficits. Gaps in guidance across states included partnering with MLL families to support student learning and supporting ongoing assessment practices. Implications for policy and research are presented that consider how state leaders can support schools and districts in attending to equity for MLLs amidst the pandemic.