dissenting, in which GOLDEN, Justice, joins.
[¶ 17] I respectfully dissent. In New York v. Belton, 453 U.S. 454, 460-461, 101 S.Ct. 2860, 2864, 69 L.Ed.2d 768 (1981), the United States Supreme Court held that, under the Fourth Amendment to the United States Constitution, an officer arresting the driver of a vehicle may contemporaneously search the passenger compartment of that vehicle, incident to that arrest. In Vasquez v. State, 990 P.2d 476, 480-89 (Wyo.1999), we rejected the minimal protection that Belton’s “bright line rule” provides, and we held that Article 1, § 4 of the Wyoming Constitution provides greater protection. Specifically, we announced that Article 1, § 4 requires the search of an arrestee’s vehicle to be “reasonable under all of the circumstances.” Id. at 489. See also Pierce v. State, 2007 WY 182, ¶ 13, 171 P.3d 525, 531 (Wyo.2007), and O’Boyle v. State, 2005 WY 83, ¶ 30, 117 P.3d 401, 410 (Wyo.2005). Yet, in the instant case, both the officer and the district court relied solely upon Belton’s “search incident to arrest” to justify the search of the appellant’s vehicle.
*1179[¶ 18] The majority lists four circumstances that it identifies as “exceptions” to the rule of Vasquez. I take that to mean that, in the majority’s view, the search does not have to be reasonable under all of the circumstances in the following instances: (1) an officer may search the area immediately available to an arrested person for weapons or other contraband that might pose a threat to officer and/or public safety; (2) the presence of a second passenger in the car who could present a threat to officer or public safety may justify a search; (3) the possible need to secure an arrestee’s automobile may justify a search; and (4) “that in such circumstances an automobile may be searched for evidence related to the crime which justified the arrest.” (Emphasis in original.) In my view, however, these are not exceptions to the Vasquez rule; rather, they are simply some of the circumstances that should be reviewed in determining whether the vehicle search was reasonable “under all of the circumstances.” Most troubling to me is the idea that the arresting officer may always search the vehicle for evidence of the crime for which the driver was arrested. If that is the rule, then Vasquez has no meaning, and the vehicle may always be searched, because an arrested driver has always been arrested for the alleged commission of some crime.
[¶ 19] The officer did not claim to have probable cause to search the vehicle, nor did he claim to have a reasonable suspicion of anything when he searched it. The district court did not find that the officer had probable cause to search the vehicle, nor did it find that the officer had a reasonable suspicion of anything when he searched it. Rather, the officer said, “I searched it incident to arrest,” and the district court said, “that is good enough.” There was not even an attempt to enunciate what could have been the basis for reasonable suspicion until the State filed its brief in this Court, in which it speculated as to types of evidence that might have been in the car (the cell phone, a copy of the protective order, diaries or notes the appellant may have taken of the victims’ whereabouts, photographs of the victims, or anything else which could show that appellant was violating the protection order). At the time of the arrest, however, the officer did not have a reasonable suspicion that those items were in the vehicle. Subsequent speculation does not make a search reasonable under all the circumstances.
[¶ 20] It is important not to confuse the concepts of searching an automobile under the automobile exception to the constitutional warrant requirement, and searching an automobile as an extension of the search of the person of the arrestee, incident to arrest. All warrantless searches are unreasonable per se, and therefore unconstitutional, unless the State proves one of the following exceptions to the warrant requirement:
• search of an arrested suspect and the area within his control;
• search conducted while in pursuit of a fleeing suspect;
• search and/or seizure to prevent the imminent destruction of evidence;
• search and/or seizure of an automobile upon probable cause;
• search and/or seizure under the plain view doctrine; and
• search resulting from entry into a dwelling in order to prevent loss of life or property.
Peña v. State, 2004 WY 115, ¶ 29, 98 P.3d 857, 870 (Wyo.2004). Belton and Vasquez do not concern themselves with the probable cause search of an automobile. Rather, they concern themselves with the first exception listed — the search of an arrestee and areas within his control. Belton says an officer arresting the driver of a car may always search the passenger compartment of the car (including containers therein); Vasquez says an officer arresting the driver of a car may only search the passenger compartment of the car if the search is reasonable under all the circumstances.
[¶ 21] I do not disagree with the-proposition that factors such as officer safety and the presence of evidence may justify the search of an arrested person’s vehicle. There simply was no showing in this case, at the suppression hearing, that those or similar factors existed. Article 1, § 4 of the Wyoming Constitution forbids the search of a *1180vehicle incident to the arrest of its driver unless such search is reasonable under all of the circumstances. The car search in this case, being purely a search incident to arrest, without justification under all the circumstances, was unlawful. The motion to suppress should have been granted, and the appellant should have been allowed to withdraw his guilty plea.