Or did he?
According to Matt Barrows of The Sacramento Bee, the 49ers will ask the NFL to review Smith's fourth-quarter throw to Michael Crabtree, an 8-yard gain that was ruled a lateral. If the NFL agrees the pass went forward, Smith's final line in a 24-3 win over the Arizona Cardinals will change to 19 of 20 for 240 yards.
Former Cardinals quarterback Kurt Warner currently owns the NFL accuracy record, which requires a minimum of 20 passes. The now-NFL Network analyst was with the Cardinals when he completed 24 of 26 passes (92.3 percent) against the Jacksonville Jaguars on Sept. 20, 2009.
If Smith is credited with another completion to Crabtree, he'll move to the top spot at 95 percent.
We watched the play in question several times, and we're not convinced the 49ers have a case. Smith plants his foot on his own 18 and throws to Crabtree, who takes a half step back before making the catch.
It didn't look like a forward pass to us, but we'll leave this one to The People Who Decide These Things.
Follow Dan Hanzus on Twitter @danhanzus.