has a duty to defend “if a plaintiffs factual allegations potentially support a covered claim,” it has never applied the “potentiality” standard to deviate from the eight-corners rule. Zurich Am. Ins. v. Nokia, Inc., 268 S.W.3d 487, 490 (Tex.2008). Rather, it has used the standard to characterize the description of claims in the petition, determining whether they potentially were covered. In Zurich, for example, the Texas Supreme Court held that the allegations in the pleadings that the plaintiffs had suffered “biological injury” potentially included a claim for “bodily injury.” Id. at 492-93. It considered only the facts alleged in the pleadings and did not make any factual assumptions or inferences that were not pleaded. Id.; see, e.g., GuideOne Elite Ins. Co., 197 S.W.3d at 310 (<HOLDING>). Likewise, the Texas Supreme Court has held
holding defendants prior conviction for assault related to sexual abuse of a minor even though it did not require an act of sexual abuse because it required intent to commit sexual abuse  and such a mens rea demonstrate the offense was one relating to sexual abuse holding that merger did not apply because sexual assault was not a lesser included offense of seconddegree kidnapping involving sexual assault holding that sexual harassment need not take the form of sexual advances or other explicitly sexual conduct in order to be actionable under title vii holding that a sexual assault on a female employee was of a personal nature and not directed against the employee as part of the employment relationship holding that allegations of sexual assault by an employee of the church fell within coverage for sexual misconduct