Why underparts of poss Greater Phoebe show little color

One of my friends has expressed questions about the lack of color on the underparts of the possible Greater Pewee photos posted below.  I believe that the lightness is a function of a photographic artifact caused by having to aim upwards towards the sky close to mid-day on a sunny day.   It is a common problem with photography and why many guides warn against taking photos at mid-day.  Here is what one online source with info about photographing birds says about it:  "The most common mistake I see amateurs make is shooting in harsh, direct sunlight, say from 11:00 a.m.- 4:00 p.m. During that time the sun, if unobstructed by clouds, is too direct, and the result is too much contrast and washed out color."
SeEtta