I guess it depends on what we mean by "smart."
They are going to need to have some form of being "smart" in order to weed out spam without weeding out new, legitimate users along with it. They are also going to need to have some form of being "smart" to properly handle reports of illegal content, without leaving opportunity for "report spam" to make the reporting useless.
Outside of that, how smart the relay needs to be will depend on the use-case. There are relays out there that don't store kind1 notes at all. The only reason they exist is to store NIP-47 defined kinds to facilitate Nostr Wallet Connect transactions. Part of such a relay being efficient is being smart enough to refuse all other event kinds. On the other end of things, clients need to be smart enough to only reach out to the specified NWC relays when looking for those event kinds, and not when looking for other event kinds.
So, I think both clients and relays are going to need to have a certain level of "smarts" in order for both to be efficient. But that can definitely go overboard, trying to do too much processing on either the relay side or the client side is going to make them inefficient and unreliable.