I dont think so.
You think the feds can subpeona a Iran botnet ip address? Don't think about it too hard.
Lets say even if they did, only thing theyd get is the real subscribers information in Iran. Not the hacker.
The real guys using them would be very hard to track down, unless you know for certain that the individual would connect to the same Iran or whatever botnet zombie again, and by then you would need to sniff traffic and/or log.
Doing so would then only lead to another russian zombie that would lead to another zombie in another non us information sharing country and so on. And after several chains later, they could be at a internet cafe in fucking Zimbabwe at the end of the trail, or a connection in Greece where the hacker is using a neighbor's cracked WEP network.
The only people that are going to be caught are the kids that don't know what theyre doing and supporting them without any knowledge in computer security. (Hence the guy who got caught, which I really doubt is part of them. He's just some kid that runs irc servers it seems like). Not to mention naive kids that try to follow the movement, but at the same time, use their real names and email addresses, etc... and wonder how they got caught.
People who know what theyre doing, create a total fake persona (with someone elses real information) and never have any part of their real life, name, job or hobby ever published online. If all goes to hell, and the person is somehow 'connected to the dots' by timezone, user names, etc... That fake persona is then what the 'detective' finds. And of course that person is a real person that has nothing to do with anything.