Touting Article 37 of the United Nations Convention on the Rights of the Child [an international treaty that was signed by the United States in 1995, but never ratified], some activists propose that Graham doesn't go far enough and that juveniles shouldn't be sentenced to life without parole under any circumstances.
This article, written before the Graham decision, notes that while there are 2,388 juveniles still serving LWOP sentences worldwide, the United States became the last country currently sentencing youth to life without parole in 2008:
According to a report at the University of San Francisco School of Law website, when Israel began granting parole review in 2008 to juveniles sentenced to life imprisonment, it left the United States as the last country sentencing youth to life without parole for crimes committed under the age of 18. According to a November 2007 report by The Center for Law and Global Justice and the Frank Newman International Human Rights Law Clinic, at that point 2388 individuals around the world were serving LWOP sentences for crimes committed as juveniles. Seven were serving in Israel and 2381 in the United States.
Three days ago, this interesting opinion piece (written by a retired police officer, a Department of Justice attorney who prosecuted youth and a a former warden of San Quentin State Prison and director of the California Department of Corrections) argues for support of SB 399, a legislative bill that that would allow youth a chance at parole after serving a 25 year sentence:
Collectively, we have put or kept a lot of people in prison. Prison is where some people justly belong, many for long periods of time. But it is exactly our experience in law enforcement that causes us to agree with the Supreme Court's recent decision to abolish the sentence of life without parole for teens in nonhomicide cases.
That decision, however, did not finish the reforms needed in juvenile sentencing. There are thousands of lifers in the nation's prisons — about 250 in California alone — who as teenagers participated in crimes involving homicides. They all deserve a second chance, and at least some of them may deserve to be released.
For more information on SB 399: http://www.fairsentencingforyouth.org/legislation/sb399-text/