Yes. As with a grand mal epileptic seizure, during an CNS oxygen toxicity seizure the airway will probably be closed and an ascent would probably result in lung barotrauma. One possible result of lung barotrauma is an air bubble into the arterial system (AGE), with the resultant life threatening blocking of blood vessels in the heart or brain.
This is one of the things that was covered in detail in the PADI Rescue Course I took at Pacific Dive.
OTOH, an unconscious but limp diver probably has an open airway unless his chin is against his chest, and will naturally vent out any excess air as you ascend.