While a doctor's note recommending limited working hours may indicate a "need" for leave, it does not indicate the "reason" for leave. See Lawson-Brewster v. River Valley Sch. Dist., No. 06-58, 2008 U.S. Dist. LEXIS 33060, at *5 (W.D. Mich. 2008) (holding that a doctor's note advising plaintiff to remain off work for four days did not constitute sufficient notice of plaintiff's depression).
The Sixth Circuit has held that an employee may be terminated if "the dismissal would have occurred regardless of the employee's request for or taking of FMLA leave."See also Lawson-Brewster v. River Valley School Dist., 2008 WL 1820908, *12 (W.D. Mich. 2008) ("Plaintiff has neither alleged nor shown that she was denied benefits to which she was entitled when she took leave in March and April 2004.").Id. at 507.