  Some recent studies have implied that quantum fluctuations will prevent a
near-extremal black hole from ever attaining a state of precise extremality. In
this paper, we consider the analogous situation for the scenario of a nearly
degenerate Schwarzschild-de Sitter black hole (of arbitrary dimensionality).
For this purpose, we utilize a holographic type of duality between the
solutions of interest and the near-massless sector of (two-dimensional)
Jackiw-Teitelboim theory. After explicitly demonstrating this duality, we go on
to argue that, on the basis of one-loop considerations, a similar censorship
applies in this de Sitter context. That is, quantum back-reaction effects will
conspire to prohibit a non-degenerate Schwarzschild-de Sitter spacetime from
continuously evolving into a degenerate (i.e., Nariai) black hole solution.
