I stopped using the term "path lights" years ago. I now call them "area lights" because many are capable of so much more than just lighting path and walkways. Three years ago, I was confronted with a high end client who has a very young front garden. I couldn't rely on my usual downlighting from mature trees to light the beds. There were no mature/tall trees to hang lights in that could provide a reasonable distribution at the ground plane.
My solution was to use a number of spec grade "area lights" with a relatively flat "china hat" cap. This cap allows for a reasonably wide distribution with out glare. In addition this luminaire may be specified in heights with 6" increments from 6" to 48" inches. I ordered 18 units and installed them in the immature beds with extra wire buried below each unit. I added the extra wire in anticipation of having to relocate fixtures as the garden grew.
I up-lighted the plantings I could and scattered the area lights through out the bed... mostly successfully.
The result was a pleasing composition that avoided the problem of disembodied canopies floating above a dark horizontal plane.
George Gruel photographed the result for me and you may find the result on my web site at <http://www.wlld.us/projects/area-light/index.php>. You will find there a discussion of both my successes and failures with this technique. There is a "switch" that will allow you to turn on/off the Area Lights.
I returned to the garden last Spring and did considerable work relocating the area lighting. I loved the extra wire but will leave even more the next time. I found I needed to relocate about 1/2 of the units and mostly moved them into "voids" in the plantings. I installed 6 focusable in-grade luminaires in the lawn to illuminate the much grown canopies without disturbing the planting beneath the existing specimen trees and tall shrubs.