Rodriguez v. Equifax Info. Servs. does not exist — a fabricated AI citation

In Jordan Slach v. City of Battle Ground, the plaintiff relied on a decision labeled “Rodriguez v. Equifax Info. Servs.” for the proposition that a TLOxp background-check report qualifies as a consumer report under the Fair Credit Reporting Act. The U.S. District Court for the Western District of Washington found this citation does not exist and issued a warning to the plaintiff about the risks of providing hallucinated cases to the court.

The same filing relied on a second fabricated decision for the identical legal theory — Henderson v. CoreLogic Nat'l Background Data — meaning the plaintiff's argument that a TLOxp report triggers FCRA consumer-report protections rested entirely on two citations, neither of them real. That is a materially different risk profile than a single stray fake case buried among genuine authority: here the core legal theory itself had no real supporting precedent behind it once both citations were checked.

FCRA background-check litigation is an active, genuinely well-litigated area, which makes the temptation to lean on an AI-generated summary of “relevant case law” understandable and the resulting risk correspondingly higher — real precedent almost certainly exists on this exact question elsewhere; it simply wasn't what got cited here. The Washington district court's warning was addressed to the plaintiff directly rather than to counsel, which matters here: this was a pro se or lightly represented filing, and the ruling reads as a caution aimed at future self-represented litigants who lean on AI research tools without a lawyer's independent verification step.