Yeah, maybe. I don't know much about that corsair trimaran, though.
I assume he was headed north, since he reportedly left Cape May in the morning and was capsized aways up the coast. Wind was NNE. If the true wind was gusting, say, 25 knots that could be something over 30 knots across the deck. Shouldn't that -- combined with the reported 'very steep sea' -- be enough to give that little tri some difficulty?