Birds that do not Establish Territories

The Brown-headed Cowbird is an interesting example of a bird that is not territorial. Cowbirds lay their eggs in other birds' nests. A female cowbird scouts the egg-laying activities of birds over several acres of habitat and adds one or two eggs to the nests of other species while the owners are absent. Male cowbirds display to the female throughout its scouting area. The males follow the female wherever it goes, showing no evidence of territoriality among themselves.