That's a tough one - I can see the argument from the passenger trying to eat - I was on a European carrier last year trying to eat a meal (regulr meal service) and the person in front was reclined (asleep) and it was almost impossible as there was so little space, but I can also see the argument that the person sleeping probably should not be disturbed (as I didn't on my flight). However, if the FA made the decision, that is a whole other area!