What is the test for severance in a case where a defendant and his alleged co-defendant are charged in a sexual assault case?

"Defendants jointly indicted ordinarily should be jointly tried. Serious consideration must be given to judicial economy. The burden is on the defendant to show clear, manifest, or undue prejudice from a joint trial." United States v. Polizzi , 801 F.2d 1543, 155354 (9th Cir. 1986) (citations omitted). Severance should be granted "only if there is a serious risk that a joint trial would compromise a specific trial right of one of the defendants, or prevent the jury from making a reliable judgment about guilt or innocence." Zafiro v. United States , 506 U.S. 534, 539, 113 S.Ct. 933, 122 L.Ed.2d 317 (1993). "[L]ess drastic measures, such as limiting instructions, often will suffice to cure any risk of prejudice." Id.

"The test for abuse of discretion by the district court [in denying severance

[889 F.3d 1047]