Food-value theory states that territorial animals space themselves such that each territory contains adequate food for rearing young. The ovenbird (Seiurus aurocapilla) is often cited as a species for which this hypothesis is supported because ovenbird territory size is inversely related to ground-invertebrate abundance within territories. However, little is known about juvenile ovenbird diet and whether food availability is accurately assessed using ground-sampling methods. We examined the relationship between ground-litter food availability and juvenile ovenbird diet in mixed northern hardwood-coniferous forests of north-central Minnesota. We sampled food availability with pitfall traps and litter samples, and concurrently sampled diet of juvenile ovenbirds from stomach samples. We found that juvenile ovenbirds were fed selectively from available food resources. In addition, we found that both ground-sampling methods greatly under-sampled forest caterpillars and snails, which together comprised 63% of juvenile ovenbird diet by mass. Combined with recent radio-telemetry findings that spot-mapping methods can poorly estimate territory size for forest songbirds, our results suggest that comparisons of spot-mapped ovenbird territories with ground-sampled invertebrate availability may not be reliable tests of food-value theory.