Court interprets 12-month time period of Family Medical Leave Act as applied to chronic illness

In Davis v. Michigan Bell Telephone, the Sixth Circuit interpreted the FMLA's application to a patient -employee suffering from chronic depression.  It upheld the firing of Ms. Davis, finding that her 12 month disability period ran from its initial approval in September of 2004 until her therapist certified she was able to return to work in late December.  When she did not return to work or file additional certification in the first week of January of 2005  the Court ruled that her additional absences in January could be cause for termination, despite her application for short term disability.