I guess it's a hooded warbler, then? I was originally going by the little 
black smudge between the eye and the bill.

Do you have any flycatcher photos? I think even fall phoebes and pewees can 
prove a challenge when mixed in with migrating Empidonaxes, various age 
classes, and the often crummy views one gets while these little devils dart 
around the trees, etc.

Take care,
---Mike Busam
West Chester, OH