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Update: I had forgotten to mention calls: there were a number of standard "whit" type calls coming from the tree - some more emphatic than others, plus an occasional higher-pitched "peep" - but it was impossible to assign any call to any particular individual bird.
These empids were present in my yard in western Fort Worth on September 5, 2003. There had been a major drop-in of birds (with six species of vireo and seven species of warbler) that included many empids and other Tyrant flycatchers. There is a small patch of fruiting shrub below this tree, and the empids and vireos were regularly working it for insects and also taking the small berries (I saw at least three different Empids do this.) I was positioned c. 20 feet away with bins, 'scope and digital camera, and watched the "procession" for about 90 minutes. It is impossible to say how many different empids were involved, but most seemed to be Least, with one or more Yellow-bellied and one Trail's. Almost all the birds seemed to be juvs (fresh, well-marked coverts and flight feathers; generally more yellowish tones below.)

1) Least or Yellow-bellied?; does the primary tip spacing allow it to be ID-ed?:


2) I had presumed this to be a Yellow-bellied, but I am puzzled by how many features seem to match Western:- the most obvious is the eye-ring shape - but some Yellow-bellied and Least can be like this; the length of the tail seems too great for Yellow-bellied and Least; the ground color of the primaries is brown, not blackish (compare to bird above) and the tertial fringes are rather weak; in view through the telescope the contour feathers were more worn than on the other juv. Empids (seen with same conditions/distance) - this wear is visible in the pics in the scapulars; most Empid juvs molt their contour feathers on the breeding grounds, but Western juvs perform this molt much later, on the wintering grounds, such that there may be a visible (with good looks) difference in the amount of wear in these feathers. Obviously the major problem with calling this a Western is the lack of a visible crest (in the field this bird's head shape looked "standard" empid shaped) - can Western ever look like this?:


3) This one looked like a Trail's in the field; note the long primary projection:


4) I feel that this is a typical Least; note the short tail: