common occurrence in some regions of North America. In fact, the 
species will literally nest from the ground up, in a wide variety of tree 
species. Nesting on cliffs and ledges is also not unheard of (Ehrlich, 
Dobkin, Wheye ,1988). 
There are a number of reports of small flimsy nests that observers were 
able to look up through when standing on the ground. The pattern 
appears to be that first year nests are often constructed this way. 
Additional layers are applied in each successive year, resulting in the 
heavier, thicker nest that I am familiar with. 
The Kingbird 2000 March; 50(1) 
9 
