FORT LAUDERDALE, Fla. - A fast-food restaurant employee's claims that her gay supervisor discriminated against her because she is heterosexual fail because sexual orientation is not a protected category under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e, a Florida federal judge held Sept. 21 (Hilda Espinosa v. Burger King Corporation, No. 11-62503, S.D. Fla.; 2012 U.S. Dist. LEXIS 135162).