Foraging mainly on the ground, the Palm Warbler can be a lot easier to spot the the "tree-toppers".  It also frequently bobs its tail up and down as it forages, making it easier to identify.  Being named the Palm Warbler would lead you to think it nested in palm trees, but no.  It goes far to the north  where the bogs are located and nests there.  We can always count on seeing the Palm Warblers during migration.