Smith, 23, was freed on $1,000 bond Saturday following his arrest the night before.
Details of the arrest would not be released by police until Monday, WFOR-TV, Miami, said.
Smith led all NFL rookies in sacks this season with 14. He was drafted in the first round by the 49ers out of the University of Missouri.
Former Titans kicker dies in car crash
UPI Sports Results for September 20, 2014