I found a work around for what I wanted to do and am posting in case someone wants to use this in their cart.
{if $current_category.categoryid eq "xx"}
<h1>Your Category Title</h1><div style="height: 1px;">
<img style="position: relative; top: -54px;" width="715" height="150" src="http://www.image_location.com/images/title_image.jpg" alt="">
</div>
{else}
<h1>{$current_category.category|amp}</h1>
{/if}
This puts the image right over the top of the category title so that you still have the h1 tags.
I also had to use the same if/else to position the customer/dialog.tpl line. My image was too tall and placed this line in the middle of the image.