That may depend on the court involved; NM, for example, considers the vehicle to be an extension of the domicile [home].
For purposes of STATE law, New Mexico differs based on the NM Supreme Court interpretation of the NM Sttae Constitution:
“39.-Warrantless searches of automobiles require a showing of exigent circumstances. In accordance with the principles underlying Article II, Section 10 and the cases over the last seven years interpreting that provision independently from its federal counterpart, we announce today that a warrantless search of an automobile and its contents requires a particularized showing of exigent circumstances. In State v. Copeland, the Court of Appeals defined exigent circumstances as “an emergency situation requiring swift action to prevent imminent danger to life or serious damage to property, or to forestall the imminent escape of a suspect or destruction of evidence.” 105 N.M. 27, 31, 727 P.2d 1342, 1346 (Ct.App.1986).
A warrantless search is valid where the officer reasonably has determined that exigent circumstances exist. A warrantless search is invalid if, in the court’s estimation, the officer’s judgment that exigent circumstances existed was not reasonable. The inquiry is an objective test, not a subjective one, into whether a reasonable, well-trained officer would have made the judgment this officer made. If reasonable people might differ about whether exigent circumstances existed, we defer to the officer’s good judgment. On appeal, we may review de novo the trial court’s determination of exigent circumstances.”
- See more at: http://caselaw.findlaw.com/nm-supreme-court/1069052.html#sthash.H67sT0np.dpuf
So you are correct, when referencing state law.