The No Child Left Behind Act establishes federal education policy for the United States, with a heavy focus on accountability through high-stakes testing. Provisions specific to English language learners (ELLs) include the mandate for their inclusion in state math tests, even for newcomer students enrolled for less than one year. Most ELLs take their state math tests in English with few, if any, accommodations. This study provides an analysis of this policy through the case of fifth grade newcomer Cambodian students in a Texas middle school. A linguistic analysis reveals that the language demands of the state math test far exceeds the language demand of the math work the students were able to do in school (with assistance). A content analysis of the fourth grade math textbooks used in Cambodia and the Texas school district reveals the American textbook had a much higher degree of alignment with Texas math standards, and far exceeded the Cambodian textbook in terms of depth and breadth of mathematical concepts and math problems for students to practice newly learned concepts. We argue that these analyses provide strong evidence that the Cambodian newcomer students were not afforded an opportunity to learn grade-level content before the test, and that the language demands of the test are beyond reasonable for newcomer students. We conclude with a discussion of implications for needed changes to U.S. federal policy which account for the linguistic demands posed by math tests, and which provide students opportunities to learn expected math content before taking high-stakes tests.