In 2004, the Nevada Department of Corrections (“NDOC”) adopted a policy that banned a crucial practice of inmate Anthony Chernetsky’s faith, and one he had engaged in for years without incident: anointment with natural oils. Although NDOC has since amended its religious-oils policy after being rebuked by this Court in Johnson v. Baker, it continues
to forbid natural oils. And NDOC has failed to show that this ban on natural oils—of any kind or amount, and regardless of how they are obtained, used, or stored—can satisfy strict scrutiny under RLUIPA.