How have the courts treated the issue of disclosure in a civil case?

The People treat the issue as purely a discovery violation. (Pen. Code, 1054.1.) The People argue that (a) there was no violation under Brady v. Maryland (1963) 373 U.S. 83 [83 S.Ct. 1194, 10 L.Ed.2d 215] because the undisclosed information was not exculpatory, and (b) the prosecution dutifully turned over to respondent the names of the detectives who were called as witnesses, the written police report, and the physical evidence found at the crime scene. The People go on to argue that since respondent was living in the house and was present at the time of the search, he should have known about the clothing found. This was not a mere discovery violation.