United States v. William Michael Spearman
CourtCourt of Appeals for the Eleventh Circuit
Date FiledJune 18, 2026
Docket24-10300
StatusPublished
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Full Opinion
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FOR PUBLICATION
In the
United States Court of Appeals
For the Eleventh Circuit
____________________
No. 24-10300
____________________
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
versus
WILLIAM MICHAEL SPEARMAN,
Defendant-Appellant.
____________________
Appeal from the United States District Court
for the Southern District of Florida
D.C. Docket No. 9:22-cr-80173-AMC-2
____________________
Before ROSENBAUM, BRANCH, and KIDD, Circuit Judges.
BRANCH, Circuit Judge:
William Spearman was the lead administrator of an
enormous network of child pornography orchestrated through a
dark-web site referred to as “Website A.” After the FBI received a
tip from a foreign law enforcement agency (“FLEA”) that an IP
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address associated with the site was associated with Spearman’s
address in Alabama, agents obtained a warrant to search his home
and subsequently found incriminating evidence. Spearman moved
to suppress all evidence obtained in the search. The district court
denied his motion without an evidentiary hearing, and Spearman
pleaded guilty to one count of engaging in a child exploitation
enterprise, in violation of 18 U.S.C. § 2252A(g). 1 He was sentenced
to life in prison.
On appeal, Spearman challenges the district court’s failure
to hold an evidentiary hearing on his motion to suppress. He
argues that he alleged facts that, if proven, would have shown
enough “substantial participation” by the FBI in the FLEA’s search
leading to the discovery of his IP address that a “joint venture”
between the agencies occurred. He further argues that such a
“joint venture” would implicate the Fourth Amendment because
the FBI would have needed a warrant to obtain his IP address on
its own. Spearman also challenges his sentence, arguing the district
court failed to properly account for his “extraordinary mitigating
factors.”
The problem for Spearman’s suppression argument is that
while he alleged some cooperation and technology sharing
between the FBI and the FLEA, he failed to allege such
1 In exchange for his plea, the government agreed to dismiss two separate
counts against Spearman: conspiring to advertise child pornography, in
violation of 18 U.S.C. § 2251(d) and (e); and conspiring to distribute child
pornography, in violation of 18 U.S.C. §§ 2252A(a)(2) and (b)(1).
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participation by the FBI that we must consider the FLEA’s actions
as if they were taken by the FBI itself. And because such
participation is a necessary element for subjecting a foreign search
to Fourth Amendment scrutiny, the district court was not required
to hold a hearing before denying Spearman’s motion. Likewise,
the record confirms that the district court considered Spearman’s
mitigating circumstances, and the government presented ample
evidence of the depth and depravity of Spearman’s crimes, such
that the district court did not abuse its discretion in sentencing him
to life in prison. We therefore affirm on both counts.
I. Background
In this section, we recount the facts relevant to Spearman’s
challenges to the district court’s failure to hold an evidentiary
hearing and to his life sentence. The facts recounted herein focus
on the disputes central to those two challenges and do not recount
the disturbing details of Spearman’s crimes in full.
A. Spearman controls an online network profiting off
child pornography
The events leading to Spearman’s conviction begin with
Spearman’s involvement with a dark web internet domain referred
to only as “Website A.” “The [d]ark [w]eb is a general term that
describes hidden Internet sites that users cannot access without
using special software.” McMorris v. Carlos Lopez & Assocs., LLC,
995 F.3d 295, 302 n.4 (2d Cir. 2021) (quotations omitted). These
restrictions on access make it the home of many criminals and
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“other malicious actors” who utilize those restrictions to attempt
to shield their actions from the view of law enforcement. Id.
Spearman eventually became the lead administrator of
Website A, which housed many such criminals and “malicious
actors.” Id. In order to exist on the dark web and maintain
anonymity, Website A operated over the Tor network. The Tor
network allows users to operate or access websites available only
to users within the network. It also uses technology that masks the
internet protocol (“IP”) address of users. This masking ostensibly
allows users to operate anonymously without the fear that others,
including law enforcement, will be able to discover their identity.
Website A’s main purpose was to provide access to child
pornography, though it did not directly host child pornography on
its servers. Instead, it maintained a series of chat rooms in which
users could exchange child pornography by posting URL links that
redirected to another Tor network website where child
pornography was displayed or available for download. To better
facilitate the sharing of child pornography, Website A contained a
guide on how to share child pornography through links. When
users posted the links, they used “tags” with words or phrases to
describe the category of child pornography they were sharing. The
tags used included an “age” tag specifying if the content involved
babies, toddlers, or preteens; a “gender” tag specifying whether the
content involved boys, girls, or both; an “activity” tag describing
the type of sexual activity involved; and, for some content, an
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“extreme” tag specifying if the video involved “torture,” “rape,”
“crying,” or “strangulation.”
Website A took various measures to reward and encourage
users who were deeply involved in child pornography. New users
of Website A were restricted to one chat room called the Website
A “Gateway.” The Gateway’s description stated that guests who
participated by chatting and sharing child pornography could be
invited to other Website A rooms as “members.” Users who were
promoted to “member” and beyond could access other rooms,
including, for example, “Aphrodite’s Playground” (which
encouraged users to post pornographic content of children
between ages 5 and 15, but prohibited extreme content), “Tots-R-
Us” (which encouraged users to post pornographic content of
children 5 years and younger, but prohibited extreme content),
“The Library” (which was a repository of links to child
pornography without chat and which was limited to members who
had contributed significantly to the website), and a “No-Limits
Chat” (which was dedicated to “extreme topics” such as “Death,
Gore, BDSM, Hurtcore, Bestiality, [and] Scat”).
Spearman’s role in Website A started as a baseline user but
grew over time.2 In his initial posts, he included links to hardcore
child pornography. These posts allowed him increased access to
the website, and over time, he rose through its ranks to become its
lead administrator. As the lead administrator of Website A,
2 He eventually stopped posting child pornography once his leadership status
gave him access to the various chat rooms on the site.
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Spearman supervised and directed other Website A staff, helped
clean up and organize links to child pornography on the website,
ensured staff were present at all times in different sections of
Website A, presided over staff meetings, promoted and demoted
users and staff, and oversaw the day-to-day organization and
maintenance of Website A. Spearman used the username
“N****1” which he later changed to “K****,” 3 and other high-
ranking Website A users referred to Spearman as “boss.” Hundreds
of thousands of images or videos of child pornography were
accessible and distributed throughout Website A.
B. The FBI Investigation into Spearman
The FBI began investigating Website A in 2020, but at first
had very little success. Then, in June 2022, according to internal
FBI documents, the FBI’s Child Exploitation Operational Unit
(“CEOU”) “executed an operation that allowed CEOU to conduct
offensive technical operations which eventually led to the
identification of an IP address for who CEOU believes is ‘N****1.’”
Details regarding what exactly occurred during that investigation
are sparse, and no arrest was made involving Spearman at that
time. 4 Instead, at around the same time (on June 30, 2022), the FBI
3 The usernames Spearman used have been redacted by the parties’ public
filings and are not a matter of public record.
4 Notably, the N****1 username was inactive at this time and was thus not
actively being used by Spearman, who had transitioned to the K****
username, and there is no indication in the record that the FBI knew at this
time who the N****1 username was connected to. The inactivity of the
N****1 username may help explain the FBI’s apparent confusion regarding
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executed multiple search warrants regarding the website’s second-
in-command, Selwyn Rosenstein (username “Tony”), who was
subsequently arrested.
The arrest of Rosenstein allowed the FBI to access his
account, including its ability to message other members of Website
A, providing the FBI with new tools as it continued its investigation
of Website A. Through Rosenstein’s account, the FBI began
interacting with members of Website A and attempting to discover
the identities of other users. One of the tools the FBI deployed
included sending “target files” with “offensive code” to other users
of Website A. 5 When users downloaded the files, the offensive
whose IP address it had obtained in June of 2022, as the IP address it obtained
in June of 2022 did not belong to Spearman and was thus not the IP address of
N****1, despite its original “belie[f].”
5 The FBI obtained several warrants prior to using them against various
Website A users. However, despite allegedly having a warrant to execute this
same operation for the username K****, the FBI claims it never executed the
warrant. And indeed, such a warrant is not in the record. The FBI mentions
it for the first time in its brief on appeal. The reason for this absence in the
record, the FBI claims, is that Spearman did not allege below that the FBI gave
the FLEA access to Website A’s servers and directed the FLEA to search his
computer using a remote-access technique, so there was no need to produce
a warrant showing the FBI would not have needed the FLEA’s help to do so.
This may be true. However, for purposes of this appeal, given the warrant is
not in the record, we assume, as Spearman alleges, that such a warrant does
not exist.
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code caused the user’s computer to contact an FBI server and
convey to it the user’s IP address.
According to the FBI, its focus on Spearman began not with
the June 2022 offensive operation, but from tips provided by a
foreign law enforcement agency. On August 17, 2022, the FBI
received two tips from a FLEA stating that, on August 14, 2022, the
user of a specified IP address in the United States “was involved in
the management” of Website A. The FLEA advised that it had
“lawfully acquired” this information, though it did not disclose
how it did so or provide any other information about its
investigation. According to the FBI, these tips eventually led to the
identification of Spearman’s home address. Once it received these
tips, the FBI served an administrative subpoena on the internet
service provider connected with Spearman’s IP address. The
internet provider traced the IP address to Spearman’s physical
address in Alabama.
Now armed with Spearman’s home address (and his identity
as the registered owner of that physical address), the FBI was
prepared to move on Spearman. It took its findings to a magistrate
judge and applied for a no-knock warrant in November 2022 to
arrest Spearman and search his home. The warrant application did
not mention or discuss any “offensive operations” by the FBI itself.
Instead, the application focused exclusively on the tip provided by
the FLEA and the information gained from Spearman’s internet
provider. The FBI received the warrant.
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That same month, FBI agents executed the warrant at
Spearman’s home. After entering his home, FBI agents
encountered and arrested Spearman. FBI agents also recovered
several devices from Spearman’s garage which contained 19,422
images or videos of child pornography. This material included
images and videos of older children being instructed to abuse
toddlers, and of adults engaging in the sexual torture of physically
restrained toddlers.
The agents also interviewed Spearman, who told the agents
that he used the names “N****1” and “K****” on Website A. He
also told them that he was one of the four main administrators of
Website A, that he began accessing it in early 2018, that he was an
administrator of another child pornography website on the Tor
network, and that he maintained a large collection of child
pornography at his home.
C. Procedural History
After his arrest and arraignment before the district court,
Spearman moved for an evidentiary hearing on his motion to
suppress all evidence obtained from the search of his residence and
personal devices, as well as his subsequent interview. He alleged
that the FBI violated the Fourth Amendment in obtaining his IP
address, such that all the evidence subsequently discovered in the
warrant-based searches of his residence and interview were
infected by that violation.
Spearman argued that the FBI must have violated the
Fourth Amendment because the only way to obtain his Tor-
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protected IP address was through “offensive code,” possessed by
the FBI, which can remotely access a server or computer and
instruct it to send back its IP address. But, he alleged, rather than
obtaining a warrant to perform such a search, the FBI engaged in a
cooperative investigative partnership with the FLEA through
which the FLEA obtained and shared Spearman’s IP address to the
FBI instead. After all, Spearman pointed out, internal FBI
documents reported that its own offensive technical operations in
June 2022 eventually identified an IP address they “believed” was
N****1, never mentioning a foreign government, suggesting that
the FBI was so actively engaged in the joint operation that it
considered it entirely its own. 6 Spearman thus argued that when
the FLEA obtained his address, it did so as an “agent” of the FBI.
As such, Spearman argued, the FLEA’s search that identified his
address was an unlawful warrantless search in violation of the
Fourth Amendment.
The district court denied the motion to suppress and the
request for a hearing. The court emphasized the general rule that
the Fourth Amendment does not apply to searches carried out by
foreign officials in their own countries. Thus, the court held that
Spearman bore the burden to prove the “joint venture” exception
to that general rule. The district court held that he failed to meet
this burden because the evidence he cited showed no more than
6 As noted above, however, the FBI did mention the FLEA’s tips when it
applied for the November 2022 warrant.
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generalized cooperation and information sharing between the FBI
and the FLEA.
The district court likewise concluded that an evidentiary
hearing was not required. The district court “credit[ed]” the
documents attached to the pleadings—i.e., the warrant application
for the search of Spearman’s home from November of 2022, the
FLEA tip, and the internal FBI reports from June 2022. However,
according to the court, Spearman’s allegations and inferences from
those documents made only “general” and “conclusory” assertions
about the relationship between the FBI and the FLEA. The court
thus held an evidentiary hearing was unnecessary because there
were no evidentiary issues to resolve and denied Spearman’s
motion to suppress.
D. Sentencing
After his motion to suppress was denied, Spearman pleaded
guilty. In the presentence investigation report (“PSI”), the
probation officer calculated Spearman’s total offense level at 43, the
maximum offense level. Because of Spearman’s lack of previous
criminal conduct, the probation officer calculated Spearman’s
criminal history category as I. Based on Spearman’s criminal
history category of I and his total offense level of 43, the probation
officer determined that the guideline imprisonment range was a life
sentence.
i. Evidence Presented During Sentencing
At his sentencing hearing, Spearman argued that he merited
a downward variance from the guidelines range because of
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extraordinary mitigating factors, which were wide-ranging in type
and substance. In support of this argument, Spearman provided
the following information in an interview with the probation office
prior to sentencing.
Spearman was diagnosed with PTSD while in the military in
the late-1990s and with depression around 2008. He received
treatment for, among other mental conditions, chronic PTSD,
memory lapses or loss, primary insomnia, major depressive
disorder, generalized anxiety disorder, and attention deficit
hyperactivity disorder. Spearman noted that he had three children,
including an eight-year-old son with his current wife.
Spearman also pointed to his 22 years of service in the
United States Army as a factor for the court to consider in his favor.
Spearman received several military decorations, including a
Bronze Star Medal, a Meritorious Service Medal, a National
Defense Service Medal, a Kuwait Liberation Medal, a Korean
Defense Service Medal, a Global War on Terrorism Service Medal,
a Master Parachutist Badge with Combat Distinguishing Device,
and a Master Parachutist Badge. Spearman also served 3 years, 10
months, and 26 days of foreign deployments, including service in
Panama, Saudi Arabia, Qatar, Bahrain, Kuwait, Ecuador, Peru,
Antigua and Dominica, and Thailand. Military performance
reviews Spearman provided to the court described Spearman as
“an invaluable asset to both tactical and strategic intelligence unit
commanders,” “one of the most innovative officers in the
Battalion,” “an officer of the highest caliber,” “[a] true visionary,”
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“one of the Army’s finest counterintelligence technicians,” “[f]ully
ready for the most senior warrant officer positions,” and “clearly
among the finest Military Intelligence warrant officers in the U.S.
Army.”
Finally, at the sentencing hearing, Spearman presented the
testimony of witnesses of his own, including the expert testimony
of forensic psychologist Dr. Amy Swan. Dr. Swan testified that she
had conducted a personality assessment inventory of Spearman
and concluded that he suffered from a major depressive disorder, a
generalized anxiety disorder, and a somatic symptom disorder. Dr.
Swan also testified that Spearman “ha[d] one of the most severe
cases of [PTSD]” she had ever seen and that it “had resulted in
significant impairment in his ability to function on a daily basis.”
Finally, Dr. Swan testified that Spearman’s sexual abuse as a child,
ongoing business failures, and deaths within the family, when
combined with his PTSD, led Spearman to self-soothe by engaging
in irregular sexual conduct. Dr. Swan thus testified that, in her
opinion, Spearman’s offense stemmed from “a perfect storm of
events that caused him to . . . have impaired functioning.” Dr.
Swan testified that based on her analyses of Spearman, he posed
only a 2.4 percent chance of reoffending over the next 5 years.
For its part, the government presented testimony at the
sentencing hearing from several witnesses in support of a life
sentence. First, the government solicited the testimony of FBI
agent David Backlund, who described Spearman as the FBI’s most
wanted child pornography offender in the world and as the FBI’s
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“Osama bin Laden from the dark net.” Next, the government
presented the testimony of FBI data scientist John-Robert Lee
Marsh. Marsh described the content of some of the pornography
recovered from Spearman’s devices, including, among other
examples, a video in which an 18-month-old female is hung upside
down while a woman beats the child and burns her with candle
wax, several videos of the sexual torture of children 8 years old or
younger, and an image of a topless child with blood across her body
who appears to be dead.
ii. The District Court’s Findings and Sentencing
Before announcing the sentence, the district court said that
it had heard “extensive testimony [and] hours of witness
presentation” and had read, among other materials, the PSI, Dr.
Swan’s report, the parties’ competing filings, and “the entire
record.” The district court stated that it had “made sure to consider
it all, given the severity of th[e] case and the government’s
recommendation of a life sentence,” and that it had done so
“against the backdrop . . . of the statutory factors in [§] 3553(a).”
The court described the “seriousness of [Spearman’s] offense” as
“off the charts,” citing, among other factors, the “very premise of
[Website A] [as] encourag[ing] and incentiviz[ing] other deviant
individuals into posting more and more child pornography and to
do so with the expectation of rising through the ranks in the
website to attain greater privileges.”
The district court also addressed Spearman’s military service
and found that it was not a clear-cut mitigating factor. The district
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court voiced its concerns that it was “almost as if [Spearman] took
what [he] learned in the military and then perverted it into this
frightening operation.” The court also stated that Spearman was a
“pedophile” who was, “without a doubt, a danger to society,”
citing the significant collection of child pornography found in
Spearman’s home, his use of “concealment tactics
and . . . sophisticated knowledge” he acquired in the military to run
the website, his operation of other child pornography websites, and
Dr. Swan’s testimony that Spearman had some interest in children.
The court finally found that “[g]eneral deterrence” and the need to
“send a clear message that engaging in these underground
communities of child exploitation is . . . horrific and will be
penalized accordingly” was also an important sentencing factor.
The district court said that it had also considered Spearman’s
“extensive” mitigation evidence and arguments. The court
acknowledged that it was “hard to discount” Spearman’s 22 years
of military service, but found that Spearman’s service did not
warrant a variance or departure because of the “unspeakable
nature” of Spearman’s crimes and because he seemed to use his
military experience to operate Website A. Likewise, the court
found that while Spearman suffered from severe PTSD, PTSD
could not explain his decision to run a website dedicated to the
exploitation of children.
The court thus agreed with the recommendation of the
probation officer and the government and sentenced Spearman to
a guidelines sentence of life imprisonment.
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Spearman timely appealed.
II. Standard of Review
We review a district court’s decision not to hold an
evidentiary hearing on a motion to suppress for an abuse of
discretion. United States v. Cooper, 203 F.3d 1279, 1285 (11th Cir.
2000). We review for plain error any theories supporting a motion
to suppress that were not raised below. United States v. Young, 350
F.3d 1302, 1305 (11th Cir. 2003).
We also review the substantive reasonableness of a sentence
for an abuse of discretion. United States v. Butler, 39 F.4th 1349,
1354–55 (11th Cir. 2022).
III. Discussion
On appeal, Spearman challenges the district court’s failure
to hold a suppression hearing, arguing he alleged facts that if
proven would have shown a “joint venture” between the FBI and
the FLEA such that a warrant to obtain his IP address was required
to comply with the Fourth Amendment. Spearman also challenges
his sentence, arguing that the district court failed to properly
account for his “extraordinary mitigating factors.” We disagree
and affirm the district court on both counts.
A. The district court did not abuse its discretion in
refusing to hold a suppression hearing
Spearman argues that he was entitled to a suppression
hearing because he sufficiently alleged factual issues in his motion
to suppress that, if proven, would show that the FBI’s collaboration
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with the FLEA to obtain his IP address violated the Fourth
Amendment. He raises two arguments in support of this claim.
First, he argues that he adequately alleged the FBI had engaged in
a joint operation with the FLEA in order to obtain his IP address,
thus implicating the FBI in a warrantless search. Second, Spearman
argues (for the first time on appeal) that the FLEA performed a
search of his computer on American soil, thereby independently
violating the Fourth Amendment.
The government responds that the district court did not err
in refusing to hold a suppression hearing. Regarding Spearman’s
“joint venture” argument, the government argues that the Fourth
Amendment’s warrant requirement generally does not apply to
searches made by foreign authorities, and that Spearman failed to
allege any concrete facts that would suggest FBI involvement was
so pervasive that the Fourth Amendment nonetheless applies. As
for Spearman’s “any search on American soil” argument, the
government points out that Spearman did not raise this issue
before the district court, which they argue subjects the argument
to plain error review only. And because no court has embraced
this argument before, the government argues Spearman’s claims
on this ground must also fail on the merits.
We agree with the government and hold that the district
court did not abuse its discretion in refusing to hold an evidentiary
hearing.
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1. Spearman did not allege facts that, if proven,
would show a “joint venture” between the
FBI and the FLEA requiring Fourth
Amendment scrutiny
Spearman argues that the district court erred in denying his
request for an evidentiary hearing on his suppression motion
because he alleged sufficient facts that, if proven true, would have
shown a “joint venture” between the FBI and the FLEA. In his
view, he adequately alleged that the FBI evaded the Fourth
Amendment’s warrant requirement by directing the FLEA to
search Spearman’s computer to obtain his Tor-protected IP
address. He argues that if it is true that the FBI directed the FLEA
to search his computer to obtain his IP address, all of the evidence
derived from that IP address should have been suppressed. Thus,
he argues, we should remand to the district court to conduct an
evidentiary hearing on the veracity of his allegations.
The government disagrees. It argues that the Fourth
Amendment’s warrant requirement does not apply to searches
made by foreign authorities, and that Spearman failed to allege
facts showing that the narrow joint-venture exception applied. In
the government’s view, Spearman’s allegations were speculative at
best and, even if taken as true, would not require suppression.
Under the Fourth Amendment, the government is
prohibited from engaging in “unreasonable searches and seizures”
of an individual’s person or property. U.S. Const. amend. IV.
“Generally, the way to ensure the ‘reasonableness’ of any search is
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by securing a warrant.” United States v. Holmes, 141 F.4th 1183, 1193
(11th Cir. 2025). When a warrantless search is conducted absent
any “reasonable” excuse, the evidence obtained must be excluded
under the “exclusionary rule.” Murray v. United States, 487 U.S. 533,
536–37 (1988). Thus, under the exclusionary rule, a defendant who
believes evidence has been obtained in violation of the Fourth
Amendment may move to exclude the evidence. See Cooper, 203
F.3d at 1285.
Upon receiving such a motion to suppress, a district court
may elect to hold a hearing. See id. But it need not do so in all
circumstances. Instead, for a hearing to be required, “the motion
must allege facts which, if proven, would provide a basis for relief.”
United States v. Richardson, 764 F.2d 1514, 1527 (11th Cir. 1985). A
hearing is required only if the motion to suppress alleges facts that
“are sufficiently definite, specific, detailed, and nonconjectural, to
enable the court to conclude that a substantial claim is presented.”
United States v. Smith, 546 F.2d 1275, 1280 (5th Cir. 1977) (quotation
omitted). 7 In other words, the district “court need not act upon
general or conclusory assertions founded on mere suspicion or
conjecture.” Id. So to be entitled to a hearing, Spearman needed
to specifically and concretely allege plausible, detailed facts that
would show a violation of the Fourth Amendment. Richardson, 764
F.2d at 1527.
7 In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc), we
adopted as binding precedent all decisions of the former Fifth Circuit handed
down before October 1, 1981.
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Our analysis therefore begins with what is required to show
a violation of the Fourth Amendment. When the United States
receives evidence from a foreign government, “[t]he general rule is
that evidence obtained from searches carried out by foreign
officials in their own countries is admissible” and does not
implicate the Fourth Amendment, much less violate it, for the
Fourth Amendment binds only the government of the United
States. United States v. Emmanuel, 565 F.3d 1324, 1330 (11th Cir.
2009).
This “general rule” is not, however, an absolute rule. When
federal officials receive evidence from another sovereign, the
Supreme Court has said that such evidence may still be subject to
Fourth Amendment scrutiny under what has become known as the
“silver platter” doctrine. Lustig v. United States, 338 U.S. 74, 78–79
(1949). “The crux of that doctrine is that a search is a search by a
federal official if he had a hand in it,” but “it is not a search by a
federal official if evidence secured by [non-federal] authorities is
turned over to the federal authorities on a silver platter.” Id. We
have examined the “silver platter” doctrine in cases where foreign
nations provide evidence and have identified two exceptions to the
general rule that foreign-obtained evidence does not implicate the
Fourth Amendment: (1) when the mechanism of obtaining the
evidence “shocks the judicial conscience” and (2) when the
exclusionary rule would still have a deterrent effect because the
American law enforcement agency engaged in a “joint venture”
USCA11 Case: 24-10300 Document: 50-1 Date Filed: 06/18/2026 Page: 21 of 40
24-10300 Opinion of the Court 21
with the foreign law enforcement agency. 8 United States v. Behety,
32 F.3d 503, 510–11 (11th Cir. 1994) (alteration adopted); United
States v. Frank, 599 F.3d 1221, 1227–29 (11th Cir. 2010). The joint
venture rule deters American law enforcement from using
“circuitous and indirect methods” to circumvent the Constitution,
8 When foreign officials conduct a search outside the United States, we would
find a “joint venture” if “American law enforcement officials substantially
participate[d] in the foreign search, or if the foreign authorities actually
conducting the search were acting as agents for their American counterparts.”
United States v. Rosenthal, 793 F.2d 1214, 1231 (11th Cir. 1986); see also Stonehill
v. United States, 405 F.2d 738, 744 (9th Cir. 1968) (finding no Fourth
Amendment violation when American law enforcement provided
information to foreign authorities but did not participate in what would have
been an illegal raid had it been performed by American law enforcement, but
was instead carried out by a FLEA). We have never found a joint venture
when the search occurred abroad, even when American involvement was
notable. See, e.g., Rosenthal, 793 F.2d at 1230–31 (finding no joint venture
where American agents were pre