How did he do that?

Fort Worth, TX(Zone 8a)

In the back yard, not near any trees or building, I have a plastic footstool, about 1 1/2 feet tall. On it I have a plastic tray about 1 1/2" deep. In it are plastic cups about 3" tall containing late tomato seedlings. When I went out to look at them, four were eaten to the stem. At first I thought only birds could have done that, but when I moved the cups around, I found a fat cutworm curled up in the corner. How did he do that?

Philadelphia, PA(Zone 6b)

Perhaps a bird flying above dropped its dinner or the cutworm fell from nesting material being carried by a bird.
Trish

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