I agree with most everything Christian said. I have also witnessed birders call empids Gray Flycatchers based on a downward tail flicking, but I think the confusion is inexperience with empids and the lack of clarification when this field mark is being taught. All empids flick their tails downward, only Gray is special for dipping its tail BEFORE flicking it upwards. It can be a hard judgement call since this is a fast movement and other species like Dusky will flick upwards only slightly before a more significant and noticeable downward movement. In further agreement, there are other marks that should used to distinguish Gray as well; pale gray appearance, smooth round/flat head shape, long thin bill with bright lower mandible, very faint eye-ring. If you're not confident using a combination of these marks, leave the flycatcher at empid sp.
David Tonnessen
Colorado Springs
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