What is the test for establishing that a death-qualified jury was less than neutral with respect to guilt?

[80 Cal.App.3d 592] The starting point of defendant's argument here is footnote 18 of Witherspoon v. Illinois, supra. ⁴ He claims that he has, indeed, established that the jury which convicted him "was less than neutral with respect to guilt." He bases his argument on a series of studies which he analyzes in great detail. ⁵ Asserting that these "studies fill in the gap left open by the incomplete data available at the time of Witherspoon," he proceeds to argue that the death qualification of the jury during the guilt phase of his trial resulted in a denial of his constitutional rights. He also suggests that if his analysis of the post-Witherspoon studies does not convince us that a death-qualified jury is guilt-prone, we should remand the case "for an evidentiary hearing or factual referent in order to resolve the legal issues raised by appellant's attack on jury selection practices in capital cases."