City Manager of St. George, Adam Lenhard under the direction of St. George Mayor Michelle
Randall, approved a DRAG SHOW for the filming of an HBO show, overriding the City
Council members process whereby they have the authority to approve or disapprove these
events. The approval given by Adam was executed in less than two days, constituting a
violation of law and city ordinances.
Michelle Tanner, our most conservative City Council member, has called out Adam on this
egregious violation of our rights and representative form of government and has received
threats from Adam, an intimidation tactic against her, threatening her business, family, home
and livelihood and losing her qualified immunity as a government official for denouncing
violations of rights by the city manager.
At this point we are asking you to push back against this tyrannic and corrupt behavior and the violation
of law by calling and/or emailing both Adam Lenhard and Michelle Randall and asking them to step
down from their office or correct and rectify this situation by issuing a public apology to “we
the people” and Councilwoman Tanner. The threats against Councilwoman Tanner is not to
be tolerated; she is our elected official representing our voice in city matters and Adam and
Mayor Randall need to be held accountable.
Please read Tanner’s letter denouncing Adam's threats addressed to Adam Lenhard below for
Call to action:
Please call or email St. George City Offices and express your concerns
that they rammed down this lewd drag, for profit, show in our city park in downtown St.
George by the kids carrousel targeting young children and using our police department to
provide security at our expense without retribution. Lewd acts should be prevented
by St. George Police no matter where they come from. We support freedom of speech
from whomever that may be, but violation of our ordinances and civil procedures of our
representative form of government we will not.
Please call or email and respectfully demand they resign, rectify, and/or apologize to
“we the people of St. George” and Councilwoman Tanner.
Mayor Michele Randall –
435-627-4001 - email@example.com
City Services Administration –
Here is the letter to Adam from Michelle Tanner.....
St. George City Council Woman firstname.lastname@example.org
Considerable concern has been raised in our community regarding the filming of the HBO Filming Event
of We’re Here. It is my view that it was not handled well by City Management. As you know, this had
been known to the City staff and had been in planning, and was just sprung on the council at the last
minute. Again, I do not support City Management’s handling or issuance of the special event permit in
this case. I believe that other members of the City Council feel the same way. I also feel that this leads to
even larger issues of City governance, as such may relate to the roles and responsibilities of the City
Council, that should be addressed.
Without approval from the City Council, City Management issued a special event permit for the HBO
Filming Event of, We’re Here. The location requested and approved by City Management, downtown St.
George next to (and even inside) the Children’s Museum, next to the children’s splash pad area and lazy
river, as well as close to the children’s carousel, is not suited for the HBO series, We’re Here—it is rated
“TV-MA,” which allows for obscene language and other adult content which is contrary to the intended
nature of the space requested. In issuing the permit, City Management side-stepped procedural
requirements, and denied City Council members the right to thoroughly evaluate the adequacy of the
special permit itself. You informed me in a personal phone call on Friday, May 27, 2022, that City Council
members could face personal liability if they took any action to revoke the permit.
Thus, I have looked into the situation and concluded the following: City Management violated City
ordinances in several respects. First, a completed application for a special event permit must be
submitted at least forty-five (45) days before the event is scheduled to take place. City Code § 3-10-4(A).
This specific application was submitted only days before the actual event was to take place. “Applicants
for new events...that submit the application less than forty-five (45) calendar days prior to the
scheduled event shall not be accepted.” Id. Second, “[n]o advertising of a special event shall be
permitted until City approval of the special event is granted and a special event permit is issued.” Id. at
(B). We’re Here began advertising on at least as early as May 29, 2022, several days prior to the issuance
by City Management of the special event permit for the park location. This was all done, or otherwise
permitted, by City Management in error.
Third, pursuant to City Code § 3-10-7, City Management may refer an application for a special event
permit to the City Council for approval. However, this was frustrated by your specific statement to me
on the phone to the effect that “ ...if the Council goes against the advice of legal counsel then you as
individuals lose qualified immunity. So, any liability shifts to you as individuals when you go against legal
counsel.” On Friday, May 27, 2022, notwithstanding City Council’s position that was well known to City
Management, the special event permit for the Children’s Museum had already been approved.
It was also during our phone call that I explained to you that a majority of the City Council opposed
granting the special permit until a more appropriate location could be arranged, and that we should not
be ignored. You explained that it could be taken to an administrative law judge for review but still
reiterated that even if we pursued such a process, we could still be in jeopardy of losing our qualified
immunity. You warned me how difficult that could be on me, my business, and my family. You focused
largely on the fear of a lawsuit from one side, and the criticism from the community on the other—
clearly, a tough balancing act.
My response, as you will recall, was simply, “bring it on! I’ve been threatened with lawsuits often, and
even threats of loss of a job has happened during the COVID vaccine fiasco. However, I am very
concerned about how this affects, and perhaps even unduly pressures, the other Council members to be
less willing to speak freely and carry out their responsibilities.”
It is my position that your lead-out argument on this, that City Council members who voted to revoke
the special event permit could face personal liability, is an extreme position to take. Moreover, your
argument that denying the permit would violate the First Amendment rights of We’re Here is not
accurate. We’re Here is a commercial program run by a commercial entity looking for commercial gain
through use of public space. City Council has sufficient grounds under City Code § 3-10-8(A)(2), to deny a
special event permit if “[t]he proposed special event is not consistent with the intended nature and use
of the requested City property.” This event is not consistent with the chosen location. That is the reason
members of City Council voiced their opposition to the special event permit. In fact, you even told me on
our call, that there have been several attempts and offers extended to We’re Here to change locations,
but We’re Here has rejected those overtures. The way that I see it is, City Management made a bad
decision and is now scaring off members of the Council from getting involved on threat of personal
liability if they do something that results in the revocation of the special event permit.
Returning to your argument. Denying the special event permit under City Code § 3-10-8(A)(2) would not
amount to a violation of a constitutional right. On the contrary, denial under City Code § 3-10-8(A)(2)
would be entirely content neutral. The denial would have been aimed at imposing a reasonable
restriction, which is within the right of the City of St. George to do. The statute does not identify any
specific regulated activity, but rather, is written to:
[P]rovide for and encourage temporary events to occur in the city in order to create a sense of
community and enhance the quality of life for city residents. It is also the city’s intent to promote,
protect and assure the safety and convenience of residents and visitors by mitigating potential issues
which may occur as a result of the special event. This chapter is adopted to ensure that the special
events do not create disturbances, become a nuisance, threaten life, health, and property, disrupt
traffic, or threaten or damage private or public property. It is not the intent of this chapter to regulate in
any manner the content of speech or infringe upon the right to assemble, except for time, place and
City Code § 3-10-1. Adequate alternative channels of communication have been presented to HBO
(which have been denied), and the City Council’s determination would have been unrelated to any
disagreement with the message portrayed through the Filming Event. In light of all of these facts and
legal support, City Council members’ actions to deny the special event permit would have been done in
good faith, based on both subjective and objective reasoning standards. Your emphasis of personal
liability to City Council members in relation to this issue is improper. If the City is to be brought into
litigation by HBO, it would not be attributable to the reasonable, good faith actions of City Council
members in voicing their opinion, but rather, due to the language of certain City ordinances as may be
interpreted by a court of proper jurisdiction.City Management’s actions are unfair to me and to the other
Councilpersons. The debacle of the current
HBO event is on the management, not City Council. For my part, and I believe that of my some of my co-
councilpersons, we reject the strategy of the City Management, and suggest that the Mayor take an in-
depth look at this and decide what the consequences should be.