I can think of some centerboard boats that do not conform to that assertion. I've seen a whole fleet of Mercury sloops sit on the ball through some very stiff nor'easter gales. Wiannos are such rock solid boats that they would probably shrug off most hurricanes with no trouble as long as they were tied up to a strong enough set of ground tackle. A few Tripp designs come to mind as well....any centerboard boat that is left on a mooring it can possibly blow over in a squall. These boat rely on human mass for righting moment.