Accordingly, we reject the State’s invitation to adopt the federal
automobile exception under the State Constitution. We leave intact the central
holding of Sterndale — that we do not recognize, under Part I, Article 19, the
federal automobile exception as articulated in Ross, 456 U.S. at 825.
Sterndale, 139 N.H. at 449-50.
However, we take this opportunity to recognize a more limited automobile
exception to our warrant requirement. Under that more limited exception, the
police need no warrant to enter an automobile when: (1) the vehicle has been
stopped in transit pursuant to a lawful stop; and (2) the police have probable
cause to believe that a plainly visible item in the vehicle is contraband.
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