This chapter considers the relative success of court decisions accommodating certain individual Native American inmates in their religious exercise in prisons, especially the sweat lodge. These cases reveal a pattern of what officials refer to as “Native American Spirituality.” In the prison cases, Native American Spirituality emerges as a term of art from corrections management, a line on the intake form for religious preference, and keyed to the language of the federal chaplaincy manual. Prison chaplaincy programs use it in an effort to articulate what's often exceptional and irreducibly diverse about Native religious traditions and to articulate what makes them so difficult to pin down. Especially insofar as the cases largely involve a triad of intertribal practices: sweat lodges, pipe ceremonies, and access to medicinal tobacco, sage, cedar, and sweetgrass.