I think it could make perfect sense. If price is a function of supply and demand, then a rising price would indicate increased demand, decreased available supply, or some combination of both. If the dominating factor happened to be decreased available supply (e.g. because of wide-spread HODLing), then all else being equal, I would expect a rising price requiring fewer transactions.

Conversely, it seems to me it's been the massive sell-off periods when we see the largest fee spikes (ordinals notwithstanding).