What are the consequences of Proposition 7's increased penalties for first and second degree murder?

penalties to apply to murder as the offense was understood at the time Proposition 7 was passed, not as murder may later be defined based on subsequent legislative changes. They point to language in the initiative indicating the increased punishments were for persons convicted of "murder in the first-degree" and "murder in the second-degree," and claim these terms specifically incorporated by reference the then-existing definitions of first and second degree murder, as interpreted by statute and judicial authorities. In support of this argument, they rely on a tool of statutory construction discussed in Palermo v. Stockton Theatres, Inc. (1948) 32 Cal.2d 53, 195 P.2d 1 ( Palermo ), which provides: "[W]here a statute adopts by specific reference the provisions of another statute, regulation, or ordinance, such provisions are incorporated in the form in which they exist at the time of the reference and not as subsequently modified ...." ( Id. at pp. 5859, 195 P.2d 1.)