Case Explained: UNITED STATES OF AMERICA v. WILLIAM MICHAEL SPEARMAN

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-18 Docket: 9:22-cr-80173-AMC-2 The eleventh-circuit affirmed the conviction and life sentence of William Spearman, rejecting his challenges to the district court’s denial of an evidentiary hearing on his motion to suppress evidence and his claim that his sentence was substantively unreasonable. Regarding the suppression motion, the court applied the “joint venture” exception to the general rule that the Fourth Amendment does not apply to searches conducted by foreign officials in their own countries. To trigger Fourth Amendment scrutiny under this exception, a defendant must allege facts showing that American law enforcement officials substantially participated in the foreign search or that the foreign authorities acted as agents for American counterparts. The court held that Spearman failed to meet this burden because his allegations of a “partnership” between the FBI and a foreign law enforcement agency (FLEA) were conclusory and lacked specific details demonstrating substantial FBI participation, such as the FBI directing the search or providing the technology specifically to circumvent U.S. warrant requirements. The court found that general cooperation and information sharing regarding a transnational criminal enterprise did not rise to the level of a joint venture requiring a hearing. Additionally, the court reviewed for plain error Spearman’s alternative argument that any foreign search on American soil automatically implicates the Fourth Amendment; finding no controlling precedent in the circuit establishing such a rule, the court determined no plain error occurred. Regarding the sentence, the court applied an abuse of discretion standard to review the substantive reasonableness of the life imprisonment term under 18 U.S.C. § 3553(a). The court concluded that the district court did not abuse its discretion because it explicitly considered all relevant mitigating factors presented by Spearman, including his military service, mental health history (including PTSD), and expert testimony regarding his low risk of recidivism. The district court determined that these factors did not outweigh the “unspeakable nature” of the crimes, the severity of the child exploitation enterprise, and the need for general deterrence. The court noted that a district court’s mere acknowledgment of mitigating evidence is sufficient to show consideration, even if the court ultimately assigns it little weight relative to the seriousness of the offense. As a result of this decision, Spearman’s conviction under 18 U.S.C. § 2252A(g) and his life sentence remain in effect, and no further relief or remand is granted. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.