could Bill Maher have found out about his girlfriend's litigiousness with a background check?

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from wikipedia:

In November 2004, at the end of their 17-month relationship, she sued him for USD $9 million for “pain and suffering” for alleged “insulting, humiliating and degrading racial comments.” Her suit[60] stated that Maher promised to marry her and father her children, support her financially, and purchase a Beverly Hills home.
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Maher’s filing stated that “When the dating ended, [Johnson] (sic) launched a campaign to embarrass, humiliate, and extort ridiculous sums of money from Bill Maher.” Johnsen accused another former boyfriend of rape and kidnapping in 1997, and the charges were later dismissed for lack of evidence.[62] Her lawsuit against Maher was dismissed on May 2, 2005.

Would that 1997 attempt at legally lynching her boyfriend have come to light on a regular background check? Or what sort of hoops would Maher’s defense have to jump through to eventually uncover this dirt on her?