The first episode of season 3, "SO," saw Gemma Teller on the run after shooting Polly Zobelle and being framed for the death of her boyfriend, Edmond Hayes. Agent Stahl was a little too good at making other people pay for her crimes, wasn't she? The episode saw the club's matriarch lying low in a motel room while a news report on the TV talks about a mysterious plane crash. There's even a moment where Gemma seems shocked while reading the newspaper, but the show doesn't explain why she's surprised at whatever is written on the page.
It does seem a little too coincidental that season 2 ended with Zobelle escaping on a plane, with season 3 starting with news of a plane crash. Obviously, it's not clear whether Jax and the club are the ones responsible for the accident or if fate swooped in to intervene. However, because it was only in 2020 that Kurt Sutter opened up about Zobelle's escape, it isn't impossible that the villain faked his death. Since he was easy for the audience to hate and his wealthy connections made him a formidable opponent for Jax Teller and the gang, it wouldn't be too difficult to imagine him returning in a later season.
Of course, plans always change and perhaps Sutter eventually decided not to bring Zobelle back, letting the villain escape scot-free because as he already pointed out: "There's a lot of that going around these days."
