since black and white both behave like white, what's the purpose of offering to select black at all? if you don't want people to use black, can't you remove black from the list of selectable colors?
but if people absolutely want to use black, why shouldn't they be able to do that. if you change the default of new notes to be white (maybe even have mod settings for title default color and text default color?), people won't encounter the problems with badly visible black titles/text by default, but they would still be able to change color to black and then be responsible themselves.