Respectfully differ with you on this.
For one, I'm looking for a feature that would allow me to reopen *recently closed* notes not just some random subset of recently open notes.
Secondly, most (all?) web browsers for instance allow opening recently closed tabs/windows (plus months upon months of history of all webpages opened) regardless of when they were last engaged with. Surely for the average user (even a heavy user like me) the number of open notes (which is anyway limited to 20*) shouldn't be much harder to track and reopen than the number of open browser tabs/windows?
I get the impression that the scenario doesn't resonate with more users here, but I'd imagine a lot of serious Evernote users would have faced this issue at some point. I feel most users would be conditioned by the behaviour of browsers I've described above to expect to be able to reopen recently closed notes. And like I say, I feel this wouldn't be too much of a challenge to implement. For these reasons, I feel this is a fail for Evernote.
* I do have a TOC note that I've been using to track notes that I'd have liked to keep open but have been forced to close because of this 20-note limit.