Advice needed - recurring rear axle oil seal leak

Just had my 86 cj7 (dana 44 rear) into my local jeep mechanic to
replace my oil seal, bearing, retainer etc, and brake pad on the rear
axle, driver's side. When I picked it up he mentioned that he had
noticed a lot of play when he reinstalled the new axle - he guessed
that a PO had spun a bearing. Basically the bearing was not fitting
tightly into the surrounding housing. He said it seemed ok, but if
there were any problems he may have to spot peen? (weld?) the bearing
to keep it from turning.

As it turns out, it has started leaking again just a few weeks later
and I don't understand whether or not these two issues are or could be
related. He checked the axle for straightness at the time which wasn't
a problem. Anyone have any thoughts or experience with this? I will
take it back in, but wanted to have some ideas ahead of time...

Dean