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

details.

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 - michele.randall@sgcity.org

City Services Administration –

435-627-4000 adam.lenhard@sgcity.org

Here is the letter to Adam from Michelle Tanner.....

St. George City Council Woman michelle.tanner@sgcity.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

manner regulations.

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.

Michelle Tanner