I actually have some sympathy too - row 1 has no-where else to put their luggage than above. The fact that the pax in 2D put her bag above row 1 rather than above row 2, or even underneath 1E, is poor behaviour on her part.
Overhead luggage space is one of the only downsides of row 1 in my view. Especially if you're travelling with a just-fits rollaboard.