That image was placed in that spot in a means that was in violation of google terms of service. It was googlebombed into place, which is against google's rules.... so who cares.
When people search "Michelle Obama" 95% of them aren't searching for that.
With Google letting the Obama image stand, a Twitter user who identified herself as Jill Harper of Indianapolis, Indiana, suggested a different tack: Point out the person who posted the photo.
"Instead of Google deleting the photo, there should be a campaign against the person who posted the photo," she said by e-mail. "Make a publicized attack noting the outrage of displaying such an offensive photo. This way, the person who posted it would feel the public outcry to pull the photo."
Worst fucking idea ever. Lets all call her and 1 am and complain that we find this idea horrible.