Yes, spammers use every MTA available. As well as webmail services, SMTP capable scripts, and hijacked accounts using legitimate mail servers. It's likely impossible to get a statistically significant correlation between an MTA and spamminess of the mail the comes through it. When you add to that the relative ease with which an admin can control service banners or other identifiers, it is not possible to 100% confirm guilt or innocence of a sender based only on the MTA they're using.

Personally, I've seen a stronger link between the actual client a mailer uses and their spamminess, rather than the MTA.

Now, there are some highly significant signs in received headers that can help nail down a likely guilty sender, but it's difficult to make a conclusive call on those signs alone.

That is, at least in my experience.

Marc Perkel wrote:
Just a thought. I'm wondering if there are any clues the th received lines that indicate the MTA that might be used for spam detection, or rather ham detection. Do spammers ever use Exim, Qmail, Postfix?

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