If a note begins with an image, that image is drawn on the face of the note, as if it were a fill. If the note's $NameColor is automatic, the colour of the note is changed based on a colour sampled from the image, so that a contrasting title colour may be chosen automatically. If the title is still an annoyance set the $NameColor to 'transparent'. This is most easily done using the 'Color' control on Text Inspector's Title tab.
This 'fill' display process will not occur if there is any text (including spaces) before the first image in the text. If such exists, normal rendering of note text/images will occur.