Probably. His range and his acrobatics and his knack for the flashy play were unparalleled. But his arm was never that strong, and for the second half of his career (after he hurt his shoulder, I think), was probably below average. Playing on Astroturf helped him get friendly bounces on his throws to first.
Overall, I think Smith is somewhat overrated--certainly Hall-worthy but overrated nonetheless. The fans here in St. Louis remember his backflips when he ran out on the field but they are blind to his relatively weak arm. (I grew up in Chicago and now live in St. Louis, so I am a little more objective than the locals here.)