"Black" often means those who have dark pigment. Most black Americans have native American in them, but they're still black. Technically I believe that Obama is malato, but that's generally an outdated term.
But you're right a lot of people may not be aware of his Caucasian heritage. He's spoken about it before (I'm sure everyone remembers the "typical white person" comment about his grandmother), but any media biased against him would not likely want to make him appear white at all.
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