In People v. Biehler (1961) 198 Cal.App.2d 290, where five counts of robbery and burglary were alleged against four defendants, no single defendant was charged in all five offenses, and each offense was alleged against at most two of the defendants. The Court of Appeal referred to it as a "mass trial" (id. at p. 298), and found "'in the very nature of things the consolidation of such separate unconnected charges for trial could not help but be prejudicial to either or both appealing defendants'" (id. at p. 294). Despite appropriate limiting instructions, the court held reversal was necessary because "the jury might have formed the impression on the basis of the totality of the evidence that the defendants were a gang of depraved robbers, and based their determination of individual guilt as to each offense partly upon this impression." (Id. at p. 303.)