Every menuitem in a menu is focusable, whether or not it is disabled. Indicate a menuitem is disabled by setting aria-disabled="true" on the element with the role.
Source: https://developer.mozilla.org/en-US/docs/Web/Accessibility/ARIA/Roles/menuitem_role
Oops, got this wrong. And I remember it being a bit of a pain to re-factor for this in the first place. Oh well!