If this was the first "crazy eyes" photo of Michelle Bachmann, I would say that Malkin might have a point. The problem is, Bachmann looks like this a great deal when she's photographed.
The media does not have an obligation to run a flattering photo of a subject with any story that they do. In the old days, the media would be expected to use a photo that was real or genuine, but not deliberately biased. The conservative media runs photos or images of people who look like they have fangs or like they are insane without apology. Caricature in politics is old hat.