NEW YORK - The State of New York has a right to reimbursement for environmental contamination cleanup costs incurred on behalf of an insured because the state is authorized under New York law to file a direct action against an insurer for indemnification, the Third Department Supreme Court Appellate Division said May 9 (State of New York v. Zurich American Insurance Co., No. 514916, N.Y. Sup., App. Div., 3rd Dept.; 2013 N.Y. App. Div. LEXIS 3285).