I believe you can block by IP, using a filter like this one I found on some obscure forum:
Code:
header ANNOYING_SPAMMER Received =~ /255\.255\.255\.255/
describe ANNOYING_SPAMMER Mark mail from 255.255.255.255 as spam
score ANNOYING_SPAMMER 5
However, if you can, you might as well block that IP, and then your mail server won't even have to worry about them.