has potential legal liability for the attorneys’ fees that Plaintiffs seek, and the first factor “weighs heavily” in this analysis and “creates a strong presumption” that Davis is a state official with respect to issuing marriage licenses. Kreipke v. Wayne State Univ., 807 F.3d 768, 777 (6th Cir. 2015). 2.Kentucky law generally classifies county clerks as “county officials.” Whether Davis represents the Commonwealth or Rowan County is “dependent on an analysis of state law.” McMillian, 520 U.S. at 786, 117 S.Ct. 1734. The Kentucky Constitution describes county clerks as constitutional county officers. Ky. Const. § 99. Kentucky courts have also generally characterized county clerks as county officials. See St. Matthews Fire Prot. Dist. v. Aubrey, 304 S.W.3d 56, 60 (Ky. Ct. App. 2009) (<HOLDING>); see also Carroll v. Reed, 425 S.W.3d 921, 924
holding that the grant county prosecutor had a statutory duty to be legal advisor to the county clerk even though she was not embroiled in litigation in which the county was the real party in interest holding that suit against county sheriff in his official capacity was suit against county recognizing county officers as  those whose general authority and jurisdiction are confined within the limits of the county in which they are appointed who are appointed in and for a particular county and whose duties apply only to that county and through whom the county performs its usual political functions  holding that both saline county and grant county had jurisdiction to try the appellant for murder where the actual killing occurred in one county but the acts requisite to the consummation of the murder and the subsequent disposal of the body occurred in the other county holding county clerk sued in official capacity was entitled to the immunity the county enjoyed