From a biological perspective, muscle mass (actually cross-sectional area) is the only real factor that affects strength, so definition (probably over 90% due just to proportion of fat) is effectively unrelated.
That said, if you look at living humans those with enough muscle mass (CSA) to show through whatever amount of fat *are* probably stronger than similar height/massed comparables. And someone who is that combination of fat with relatively little muscle is probably weaker.
But the presence or absence or proportion of fat has nothing to do with strength.
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