Accidents are far more likely on takeoff and landing. When this happens the passengers are hopefully going to be able to evacuate, and it would really be great if people aren’t blocked into their seats because someone wanted to recline. In that case inches really do matter. Another issue is that if the airplane is coming to a sudden stop the passengers can be thrown forward (you don’t have a shoulder strap, remember?) and if the person in front of you has their seat back in your face you will have a bad time.
With all of that to consider, instructing passengers to bring their seats fully upright isn’t that big an ask.
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