The emergence of the COVID-19 pandemic in early 2020 led to unprecedented shifts in American education. Prior to the onset of the pandemic, children across the United States were primarily educated in brick-and-mortar school buildings, with only 0.6% of the over 50 million students in the country attending fully virtual schools (National Center for Education Statistics, 2020). By March 2020, K-12 school buildings across all 50 states began to close their doors, eventually pivoting from traditional, in-person learning to some form of distance education. While all students were affected by school building closures, of particular concern was the experience of students with disabilities, whose right to a free, appropriate, public education in the least restrictive environment is governed by the federal Individuals with Disabilities Education Act (IDEA, 2004). Using a multi-layered case study design, this dissertation examined how one state, district, and school implemented special education policies during the COVID-19 pandemic. This dissertation drew on multiple data sources, including state and district policy documents, interviews with leaders and teachers, and school committee meeting transcripts. Using policy as discourse (Bacchi, 2000) and sensemaking theory (Coburn, 2004; Spillane et al., 2002) as theoretical frames, I make three key arguments. First, I argue that legal and regulatory, structural, and local forces acted on the special education policy context during the COVID-19 pandemic. Second, I argue that these forces were mediated by three factors: "congruence" with existing policy messages, perceived "legitimacy" of new directives, and the "coherence" of policy enactment. These arguments build toward my third, overarching argument--that educators and caregivers in City district made sense of special education policy during the COVID-19 pandemic by engaging in a process of "equilibration." This dissertation concludes with the implications for research, policy, and practice related to future times of educational emergency. [The dissertation citations contained here are published with the permission of ProQuest LLC. Further reproduction is prohibited without permission. Copies of dissertations may be obtained by Telephone (800) 1-800-521-0600. Web page: http://www.proquest.com/en-US/products/dissertations/individuals.shtml.]