When I learned it (and what I accepted as fact?!?) was that Nitrogens rapidly interconvert between R and S, therefore giving them chirality. As was mentioned, tertiary nitrogens might have a bigger energy barrier to rotation, however I am somewhat certain that it is, in fact, always, chiral. Unless, of course, it is a Carbon DB Nitrogen. Then no free rotation….and no stereo center
.
-Zack