I was sitting in J on AA 10 LAX-JFK (the 9:30 PM departure) a couple of months ago. I really wanted to sleep during the flight and popped an Ambien just after boarding. We unfortunately had a bit of a delay, and after dozing off, I woke up in a slight haze and made the mistake of reclining my seat to get more comfortable. It turns out that we were still on the ground, and my recline was met by a swift kick to the back of my seat from the passenger behind me who shouted, "It's meant to be up!" in a British or possibly Australian accent (I can usually tell, but was a bit out of it

) that was loud enough for the entire cabin to hear.
I was shocked and have never directly experienced that type of aggressive behavior from a fellow passenger before. I likely would have responded somehow under normal circumstances, but really wasn't in the mood, so I just kept my seat upright and eventually reclined for the rest of the flight once we were finally in the air (without any further issues).
I can't imagine ever just shoving the back of someone's seat like this guy did, regardless of who was right or wrong. I would always attempt to ask politely and then speak to an FA if there were truly an issue.