Juvenile Semi-palmated Sandpiper?

Sandpipers are worse than gulls to ID. I need help on this one!

Phil -

Peeps are hard. I assume this photo was taken in the summer. On that assumption, I can narrow it to either a Western or Semipalmated. The bills is short for a Western, but the head is turned slightly away and bill length is variable, anyway. The supercilium - the "eyebrow" - isn't very strong, which argues for a Western. The chest coloration runs pretty low, which also argues for a Western. The bill tip doesn't droop, which argues for a Semi, but that's not definitive in a juvenile.

Bottom line: more likely a Western than a Semipalmated, but I can't be definitive. Do you have other shots?

Nice photo, by the way. The low angle really helps.

I'm no peep expert, but that bill looks kinda ploverish.

Actually Jim, I took this today. Sorry, I should have said that. Here is another shot with an OOF laughing gull for size comparison.

Buck's right, it's a black bellied plover in its non-breeding plumage.

Definitely Black-bellied Plover. I had assumed it was a summer shot. All Peeps in North America are long since out of breeding plumage.

Thanks, everyone.