It would seem that this is still a problem for this scenario as I've just hit it :(
If your SmarterMail server usually sends out via a gateway server, then the SmartHost feature needs to be able to be told to ignore the gateway when attempting to redeliver the mail. Otherwise, as Demps wrote back in 2005, the gateway server will attempt to send to the mail to the primary MX entry server (which is still down) and so will then send on to the backup MX server - ie, straight back to your SmarterMail server which is acting as the backup. You now have a lovely little mail loop! 
Basically, if you use a gateway to send outbound e-mail then you can't/shouldn't be acting as a secondary mx for another server while that server is down until this issue can be fixed by SmarterTools 