The Purple Heart is awarded to those killed or wounded in action against the enemy, Mike. The fact that he was KIA entitled him to the PH. In case you don't have it, his info listed with the ABMC is:
Smiley A. Orr Serial Number: 37634647 Entered the Service From: Missouri Rank: Private First Class Service: U.S. Army, 18th Infantry Regiment, 1st Infantry Division Died: Wednesday, March 21, 1945 Buried at: Henri-Chapelle American Cemetery Location: Henri-Chapelle, Belgium Plot: G Row: 7 Grave: 37 Awards: Purple Heart
You can also send for his Individual Deceased Personnel Files (IDPF). As others in this forum have addressed, the info found in an IDPF can be graphic. If you pursue this resource, you should be prepared for that possibility. Send your request to: US Total Army Personnel Command ATTN: TAPC-PAO (FOIA) 200 Stovall Street Alexandria, VA 22332-0404 Be sure to cite the Freedom of Information Act in your request.