Hello CorytonSLF and welcome to the cabin of PPRuNe. Yes it does matter that seats are upright for take and landing as that is the position where they are set for maximum protection of the person during a rapid deceleration - howsoever caused. All seats have to be in the same configuration to benefit each SLF equally.
I suspect that it was an oversight by the attendant but there might have been extenuating reasons. Let's see what others say.