Linear and energy theory stability criteria are presented for fluid layers of infinite horizontal extent heated internally by a uniform volumetric energy source. The thermal coupling between the layer and its environment is modeled by a general mixed boundary condition in both the conduction state and the disturbance temperature. Rigid-rigid, free-free, free-rigid, and rigid-free boundaries are considered in the computations. For a fixed ratio of upper surface Biot number to that at the lower surface, decreasing the Biot number is strictly destabilizing for both linear and energy theory criteria. A region of possible subcritical instability is found; its size is strongly dependent on Biot number and becomes small for small values of lower surface Biot number and large Biot number ratio. For two rigid surfaces and an upper and lower surface Biot number of 47.5, mean energy transport measurements within the convecting layer indicate a critical Reyleigh number close to that predicted by linear theory. Subcritical instability is not observed when finite amplitude disturbances are introduced at a Rayleigh number between the critical values predicted by the linear theory and the energy theory.