In People v. Gutierrez, 58 Cal. 4th 1354, 171 Cal. Rptr. 3d 421, 324 P.3d 245 (Cal. 2014), the California Supreme Court concluded that recent legislation had failed to remedy the imposition of presumptive life sentences without parole for juvenile homicide offenders. Id. at 266-67. The legislation permitted such offenders to petition for resentencing after serving fifteen, twenty, or twenty-four years in prison. Id. Noting the Supreme Court's emphasis in Miller on individualized sentencing, the court concluded this was insufficient to remedy a sentencing court's "underlying judgment of the offender's incorrigibility 'at the outset,'" and remanded the cases for resentencing. Id. at 267, 270, quoting Graham, 560 U.S. at 75.