In United States Fidelity and Guaranty Company v. Federated Rural Electric Insurance Corporation, 2001 OK 81, 37 P.3d 828, in answer to a certified question submitted by the Court of Appeals for the 10th Circuit, the Supreme Court declared that an excess insurer is not liable to the primary insurer under the doctrine of equitable subrogation. In its discussion distinguishing between the doctrines of equitable subrogation and equitable contribution, the Supreme Court noted that equitable contribution is the right to recover from a co-insurer who shares common liability with the party seeking contribution. The doctrine applies only when co-insurers have covered the same insured and the same particular risk at the same level of coverage. However, in that case, the Supreme Court did not make a determination that the doctrine of equitable contribution is the law in Oklahoma.