Deserving of a call-up, sure, but there are only 26 spots available on the MLB team, and he's also not on the 40 man roster, and because of all the people we have on the 60 day IL right now, the limited dead weight on the 40 man will have to be cut for (some of) those returning players.
Logistically, there's no room for Smith at the moment (barring a trade in which he's not involved.)