Any competitive game(or lobby) that can have smurfs, will have smurfs.
Smurfy's law describes the fact that in any game where players compete, and the game has any kind of matchmaking system, there will be high level players that deliberately place into lower levels so they can more easily win.
Person 1: Man, I play this game for fun and to relax. I can't believe there are people smurfing in casual!
Person 2: You know how it is. Smurfy's Law.