He ran for re-election in the 1991 Northwest Territories general election defeating 2 other candidates to win his second term in office.
Zoe ran for re-election in the 1999 Northwest Territories general election but was defeated by Leon Lafferty.
Zoe would run again in the 2003 Northwest Territories general election this time defeating Lafferty.
After winning re-election to his third term in 1999, Zoe was appointed by Premier Joe Handley to the cabinet as Minister of Municipal Affairs and Community development.
Zoe became mired in scandal on May 15, 2004 after a night of drinking at the Royal Canadian Legion in Yellowknife, when he was overheard making derogatory comments about Newfoundlanders.