J.R. Smith, as he tends to do, got himself in a bit of hot water Monday night against the Atlanta Hawks.
In the third quarter, Smith hit Hawks forward Paul Millsap in the face with an elbow. The elbow, while seemingly inadvertent, prompted the officials to review the play. After the review, Smith was called for a Flagrant 1 foul. On the play, Smith wasn't really doing anything dirty - he was simply trying to establish position against a much larger, stronger player in the post.
Smith, if you remember, was called for a flagrant-2 last year after striking Boston Celtics forward Jae Crowder in the face. He has also shoved and slapped opposing players in the past. Considering the relative lack of harm here, his past actions certainly couldn't have helped him here.