Way back in 1999, in a Usenet discussion thread about Sanford, one of my fellow spam fighters asked this question: "My question would be when Wallace is going to find another loophole that allows him to cost-shift his advertising? If he could find a way to print flyers and get them glued onto everyone's car, then sue them for removing them, I'd bet that he'd do it. He's just that kind of scumbag."
Uh, well, here's something. "Last August, Wallace admitted to compromising around 500,000 Facebook accounts, using them to send over 27 million spam messages through Facebook's servers, between November 2008 and March 2009."
Looks like that'll get him about two years in prison.
ETA: More on Sanford and where he fits into spam history from Laura Atkins.