In 2003, 14-Year-Old Evan Miller Beat His Neighbor to Death

In 2003, 14-year-old Evan Miller beat his neighbor to death and burned down his trailer. Miller was convicted in 2006 and sentenced to life without the possibility of parole (LWOP) , which is the mandatory sentence for "murder in the course of arson." The Supreme Court found in the case bearing his name, Miller v. Alabama, that mandatory life sentences for juveniles were unconstitutional, although the court did not ban them outright. The court had already ruled against life sentences for juveniles in 2010. Why didn't this finding apply to the Miller case?

A) The 2010 finding was not applied retroactively, so it would not have impacted Miller because he was convicted in 2006.
B) The 2010 ruling rejected life sentences for nonhomicidal offenses.
C) The 2010 ruling was not applicable to Alabama.
D) The 2010 ruling was only applicable for juveniles that were not tried as adults.