I'm not entirely sure because the naming linting does apply to query names, but not fragment names (on relay v14.0.0)
In the code for the graphql-naming rule I see this:
const CREATE_CONTAINER_FUNCTIONS = new Set([
  'createFragmentContainer',
  'createPaginationContainer',
  'createRefetchContainer'
]);
It seems like it's just checking these container functions which aren't in the latest relay which uses hooks like useFragment.