What is the current state of the law on juvenile offenders sentencing for life in prison without possibility of parole?

Most recently, in Miller v. Alabama (2012) ___ U.S. ___ [132 S.Ct. 2455], the court held that "the Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile offenders." (Id. at p. 2469.) Rather, the sentencing authority must "take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison." (Ibid., fn. omitted.) Its task is to distinguish "between 'the juvenile offender whose crime reflects unfortunate yet transient immaturity, and the rare juvenile offender whose crime reflects irreparable corruption.' [Citations.]" (Ibid.)