Guesses?

[Dinusaur]

What a 'misnomer' for an orange-crowned warbler :?

[Pat Hodgson]

Yes, I see what you mean that OCWA can have a gray-headed look that is very close to this bird, and you are probably right in this case.  But there are mourning warbler pictures out there that are awfully similar too (of course we have to take ID'd photos on the web with a grain of salt) like this one:  http://www.pbase.com/image/116799088.

[thouc]

I just discovered the clincher: Mourning Warbler has long, pink legs, Orange-crowned has short, dark legs (as our bird has).

[Brian Bailey]

I just discovered the clincher: Mourning Warbler has long, pink legs, Orange-crowned has short, dark legs (as our bird has).

Very good!  I rarely think to look at the leg colour of warblers even though I know it can be diagnostic.  (Think female Cape May vs Blackpoll.)

BB

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[Bluffs Birder]

As we normally view most birds from the underside and side in the field, I'll just add one other feature to watch for when trying to ID Orange-crowned Warblers and Mourning Warblers.  From below, the Mourning Warbler has long undertail coverts (the feathers that are located in the area from it's legs to it's tail) and a much shorter tail compared to the Orange-Crowned Warbler.

Walter