Smith has been charged with the murders of two brothers and another man who were kidnapped and robbed before they were killed.
A criminal complaint filed earlier this week in Los Angeles charges Smith with murder with special circumstances, making him eligible for the death penalty.
The former NFL player is currently awaiting retrial in the 2008 murder of Maurilio Pence. A jury failed to reach a verdict in April.
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Smith was charged with the November 1999 slayings of brothers Kevin and Ricky Nettles and the 2001 death of Dennis Henderson.
A phone message left for defense attorney Michael Evans was not immediately returned Friday.
Smith was a defensive end with Oakland and later the Los Angeles Raiders of the National Football League from 1991 to 1998.