What are the consequences of a conviction and sentence of life without parole for a robbery-murder special circumstance?

Defendant was found guilty of first degree murder (Pen. Code, 187, subd. (a), 189), with a robbery-murder special circumstance (Pen. Code, 190.2, subd. (a)(17)(A)), and sentenced to life without parole. In 2014, the trial court granted his habeas petition so that he could be resentenced pursuant to the constitutional standards for the imposition of a life sentence on a juvenile set forth in Miller v. Alabama (2012) ___ U.S. ___ [132 S.Ct. 2455]. Once again, however, defendant was sentenced to life without parole.

Defendant appeals. Because the trial court did not abuse its discretion, we will affirm.

A. The Commitment Offense.