How has the court applied strict scrutiny to a race-based equal protection claim?

Our adoption of the intermediate scrutiny standard "should not be read to mean that deference [to prison officials] plays no role in prisoners constitutional claims." Harrington v. Scribner , 785 F.3d 1299, 1307 (9th Cir. 2015) (discussing the application of strict scrutiny to a race-based prison claim). Under heightened scrutiny, the deference owed to judgments made by prison officials is factored into the importance of the government's asserted interest; stated differently, "penological interests may still factor into the analysis of an equal protection claim" because such considerations "properly inform whether there exists a[n important state] interest." Id. at 1308 (but noting that in considering a race-based claim, those considerations "do not excuse the narrow tailoring requirement").