The MacGillivray’s warbler (Geothlypis tolmiei) is a small species of New World warbler. These birds are sluggish and heavy warblers with short tails, preferring to spend most of their time on, or near the ground, except when singing.
The MacGillivray’s warbler was named by John James Audubon in honor of Scottish ornithologist William MacGillivray, although the proper credit to its discovery goes to John Kirk Townsend. The scientific name “tolmiei” was given in honor of William Fraser Tolmie. source