I think using smart case as the default would make the rg utility slightly more useful as it would then automatically try to detect whether it should search case sensitively or not. This is also the same behavior as the one in the program ag.
The change would simply changing the flag -i to -S. I have pasted a patch below if that's helpful.
From b2d7624c1541ec3e7afeac80c9013b8d880bb09a Mon Sep 17 00:00:00 2001
From: =?UTF-8?q?Jan=20Niklas=20B=C3=B6hm?= <firstname.lastname@example.org>
Date: Thu, 31 Aug 2017 15:42:09 +0200
Subject: [PATCH] Use smart case instead of ignoring it
counsel.el | 2 +-
1 file changed, 1 insertion(+), 1 deletion(-)
diff --git a/counsel.el b/counsel.el
index 5d2f129..92850c5 100644
@@ -2043,7 +2043,7 @@ This uses `counsel-ag' with `counsel-ack-base-command' replacing
-(defcustom counsel-rg-base-command "rg -i --no-heading --line-number --color never %s ."
+(defcustom counsel-rg-base-command "rg -S --no-heading --line-number --color never %s ."
"Alternative to `counsel-ag-base-command' using ripgrep."
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