Does the prosecution have a duty under the Fourteenth Amendment to disclose evidence to the defense?

" 'The prosecution has a duty under the Fourteenth Amendment's due process clause to disclose evidence to a criminal defendant' when the evidence is 'both favorable to the defendant and material on either guilt or punishment.' [Citations.] Evidence is 'favorable' if it hurts the prosecution or helps the defense. [Citation.] 'Evidence is "material" "only if there is a reasonable probability that, had [it] been disclosed to the defense, the result ... would have been different." ' [Citations.]" (People v. Earp (1999) 20 Cal.4th 826, 866.) "In deciding whether evidence not disclosed to the defense was material under these standards, we consider how the nondisclosure affected the defense investigation and trial strategy. [Citations.]" (In re Bacigalupo (2012) 55 Cal.4th 312,

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