In Loving v. Virginia (1967), the Court applied strict scrutiny, but said that white supremacy is not a legitimate state interest, which showed that perhaps a lower level of scrutiny could have been used to declare the law unconstitutional.

Q: Based on the fact that the Court in Loving found that white supremacy is not a legitimate state interest, what is an argument that strict scrutiny isn't needed in affirmative action cases where a white Plaintiff is claiming unequal treatment (like in Regents of University of California v. Bakke 1978)?