
Statistics by sports data provider Opta showed Grealish was fouled nine times in Sunday's 2-1 defeat by Chelsea -- the most on one player in a single game this season.
His tally for the campaign stands at 140, with Crystal Palace winger Wilfried Zaha the next most targeted player, drawing 98 fouls this season.
"Jack has had a marker on him all season...," Smith told reporters ahead of Wednesday's league trip to Newcastle United.
"The most surprising stat will be that there's only about five bookings for those 140 fouls.
"The officials probably need to protect him more for sure. He's got bruises all over his shins and his side."
Villa are second from bottom with eight games remaining.
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