On December 30, 2004, a three-judge panel of the reversed that decision on the grounds that the federal courts lacked jurisdiction to overrule the probate court decision.
In the early 2000s, Smith had very few acting roles.
Despite rumors of methadone use due to its involvement in the death of Smith's son, Perper only found methadone in her , indicating it was probably ingested 2—3 days prior to her death, and therefore was not a contributing factor.
A black granite monument was installed at Smith's grave in the Bahamas in February 2009.
Smith appeared as herself in the 1995 of , then attempted to revitalize her film career with a leading role in in 1996.
The employee at the front desk in turn called the hotel security guard, who then called.