What is a reasonable probability of a different result if the prosecution did not disclose impeachment evidence as to a witness?

The reasonable probability of a different result is "assessed by considering the evidence in question under the totality of the relevant circumstances and not in isolation or in the abstract." (In re Sassounian (1995) 9 Cal.4th 535, 544.) For example, where the prosecution did not disclose impeachment evidence as to a witness who provided crucial evidence of guilt, and the remaining evidence on the critical issue was relatively weak, a court may conclude there was a reasonable probability of a different result sufficient to undermine confidence in the outcome had the evidence been disclosed. (In re Pratt, supra, 69 Cal.App.4th at pp. 1312, 1315-1322.) In contrast, the nondisclosure of documents prepared by a witness (and a detective's notes of interviews with her) that could have impeached significant portions of her testimony was found harmless in Strickler v. Greene (1999) 527 U.S. 263 because the totality of the relevant circumstances, including the testimony of three other witnesses placing the defendant

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