Although Kassomi frames much of his appeal in terms of due process violations, his actual arguments are couched in terms of whether there was an abuse of discretion and are therefore reviewed as such. Cf. United States v. Lira, 262 Fed.Appx. 653, 656 (5th Cir. 2008); Ogunfuye v. Holder, 610 F.3d 303, 307 n.4 (5th Cir. 2010). To the extent Kassomi intended to raise procedural due process arguments beyond the alleged errors presented to the BIA, those arguments are not properly before this Court because Kassomi did not exhaust them before the BIA either on direct appeal or through a motion for reconsideration.
merous times that the relationship between co-defendants does not require reversing the denial of a motion to sever. See, e.g., United States v. Nguyen, 493 F.3d 613, 625 (5th Cir.2007) (concluding that the district court did not abuse its discretion when it denied a motion to sever filed by a defendant who was being tried with his twin brother); United States v. Solis, 299 F.3d 420, 441 (5th Cir.2002) (rejecting the defendant's argument that “he was convicted on guilt by association” because he was tried with his brother); United States v. Bermea, 30 F.3d 1539, 1572–73 (5th Cir.1994) (determining that the district court did not abuse its discretion by denying the appellant's motion to sever even though the appellant was tried with three family members, one of whom pleaded guilty part way through the trial); United States v. Partin, 552 F.2d 621, 640–41 (5th Cir.1977) (affirming the denial of a motion to sever where the defendant was tried with his father-in-law and brother); see also United States v. Lira, 262 Fed.Appx. 653, 655 (5th Cir.2008) (unpublished) (holding that even if some of the evidence against the appellant's husband was not relevant to the case against her, the district court did not abuse its discretion by denying the appellant's motion to sever her case from her husband's case because “the district court instructed the jury to give separate consideration of the evidence as to each defendant”). The fact that Kirkwood and Owens were living together and had been dating for three years at the time of the robbery is insufficient to warrant reversing the district court's ruling.