It probably mainly depends on the available space. Docile individuals of most species might do well in trios in normal cages, but in general you are likely to need an aviary to make a trio work long term.
I had a trio of button quail in my room once. The cage was 2x5 ft, so a pretty decent size. Everything was well for half a year, then spring came with all its hormones and one hen kept chasing the other - they were sisters and raised together so they had had an established pecking order for a long time. I moved them to a 4x10 ft aviary and they have been fine for two years like that by now, even raising chicks together.
