Is a county sheriff a state rather than a county officer?

The majority concludes that county sheriffs, when performing law enforcement functions, are state rather than county officers and thus immune from section 1983 lawsuits. (Maj. opn., ante, 11 Cal.Rptr.3d at p. 695, 87 P.3d at p. 4.) Central to that conclusion is this court's decision in Pitts v. County of Kern (1998) 17 Cal.4th 340, 345, 70 Cal.Rptr.2d 823, 949 P.2d 920 (Pitts), in which the majority held that a county's district attorney acts on behalf of the state in prosecuting crimes, in establishing policy, and in training prosecutorial staff. Acknowledging that "Pitts involved district attorneys rather than sheriffs," the majority here is quick to point out that Pitts "relied on statutes and analysis applying to both kinds of officers" and thus applies with equal force here. (Maj. opn., ante, 11 Cal.Rptr.3d at pp. 697-698, 87 P.3d at p. 6, italics omitted.)