this would coincide with our original finding which was there was a large pressure drop across the filter due to insufficient number of holes in the center support and a bypass spring that was set on the high side.
Incidentally many filters have quite a low bypass setting which causes the filter to run in bypass mode most if the time. Most filters will do that during startup, but some do it pretty much all of the time since the bypass is set so low. The Fram we looked at was only around 2 psi (this was for the basic cheap Fram, not the new premium filter that they offer now)! Of course the best is a filter that has lower resistance (generally one with more filter area) so that high filter flow is maintained without a large pressure drop.
As you can see the By-Pass (relief) P.S.I. is 14-18 not 2 psi...YUP...
This is the one I use ~ It is a little longer, but does not sit lower than the oil pan ~ I spray it flat black, as the filters on Smart can be seen from the rear ~ I change oil & filter every 5,000.