I've found them difficult to photograph. Most of the time it is because they are foraging in thick underbrush, and they never seem to sit still. A case in point: I got a nice shot of the Towhee above at Silver Lake near Mt. St. Helens in Washington at Christmastime. But it never turned around to show its colorful breast.
Finally, I was out on the Tuolumne Parkway Trail today for the first time since the storms began, and I saw another Towhee foraging in the open. I got the side shot I wanted, so I was finally able to cobble together this post, from three different locations and with three different birds.