The typical spin-on oil filters many of our vehicles use are supposedly "full-flow" designs, meaning all the engine oil passes through the filter. However, the way many filters are designed it appears very likely that some oil leakage around the filter element occurs fairly often if not constantly. I know that some vehicles have in-engine bypass valves (I have an Impala with one) and therefore the filters don't require a bypass valve, but many more vehicles specify a bypass in the filter. The ones I have examined appear to be rather poor at sealing, and often just sit on one of the filter endplates with metal-to metal contact--no gasket or seal of any sort between the valve assembly and the endplate. On many filters, notably say Fram TGs, the bypass valve assembly just sits in a cutout in the cardboard endplate. These designs must leak a fair bit of oil in operation, and of course they also open up at times during cold starts or hard acceleration. It seems that vehicle and filter engineers are not too concerned with "dirty oil" bypassing the filtration medium.