What is the current state of the law on "plain view" searches?

"If an article is already in plain view, neither its observation nor its seizure would involve any invasion of privacy. Arizona v. Hicks, 480 U.S. 321, 325 [107 S.Ct. 1149, 1152-1153, 94 L.Ed.2d 347] (1987); Illinois v. Andreas, 463 U.S. 765, 771 [103 S.Ct. 3319, 3324, 77 L.Ed.2d 1003] (1983). A seizure of the article, however, would obviously invade the owner's possessory interest. Maryland v. Macon, 472 U.S. 463, 469 [105 S.Ct. 2778, 2782, 86 L.Ed.2d 370] (1985); [U.S. v.] Jacobsen, 466 U.S. [109] 113 [104 S.Ct. 1652, 1656, 80 L.Ed.2d 85]. If 'plain view' justifies an exception from an otherwise applicable warrant requirement, therefore, it must be an exception that is addressed to the concerns that are implicated by [81 N.Y.2d 111] seizures rather than by searches" (id., 496 U.S. at 133-134, 110 S.Ct. at 2305-2306 [footnotes omitted].