G.B.
i would probably use it and just put down some innocuous reason. If they do call and check there are very limited questions they can ask.
BUT! The tone the person uses to answer the question and the phrases they use can make and entirely different impression.
For example:
"Hi, this is Jim from XX designs calling to verify the employment of a E. S. Doe. Can you confirm that person worked at this business?".
"Who? You mean E Doe? You want to know if she "worked" here, (they start laughing) um yeah, she "worked" a "lot"...(Still snickering and laughing)".
Jim " Can you confirm the dates she was employed by the company"?
"Um, hang on, I'll have to look that up..............I had to look all over the office, everyone has been "looking" at this file".
So you can see that even though they did not say anything illegal they did imply that E. S. Doe was a lazy employee who did nothing during the time they were employed and that there may be issues still pending from there leaving since everyone is still reading their files.
So it this past company has hard feelings towards you I might just skip them and not say anything. But if they are professional in any way I would go ahead and put them down.
Also, if the job is no way related to the type of company this new possible employer is then I might leave them off anyway.
I had 2 different resumes. One that the cover letter, education awards and special programs focused on Child care and a totally different one that focused on working with people who have developmental disabilities.
I have had so many jobs that were so related to my areas of work that i just could not have put them all down. If you are doing a background check for a job such as a police officer then I would put down each and every one of them with all the gory details of why they didn't work out. But for just a normal job I did not list all of them each time.