 The phrase "heightened scrutiny" has been used interchangeably with "intermediate scrutiny" but it is unclear if the two are actually legally interchangeable.In "Witt v. Department of the Air Force", 527 F.3d 806 (9th Cir.2008), the United States Court of Appeals for the Ninth Circuit ruled that the law commonly known as "don't ask, don't tell" (DADT) was subject to "heightened" scrutiny based on its analysis of "Lawrence".