A rigorous bound is derived which limits the finite-amplitude growth of arbitrary nonzonal disturbances to an unstable baroclinic zonal flow within the context of the two-layer model. The bound is valid for conservative (unforced) flow, as well as for forced-dissipative flow that when the dissipation is proportional to the potential vorticity. The method used to derive the bound relies on the existence of a nonlinear Liapunov (normed) stability theorem for subcritical flows, which is a finite-amplitude generalization of the Charney-Stern theorem. For the special case of the Philips model of baroclinic instability, and in the limit of infinitesimal initial nonzonal disturbance amplitude, an improved form of the bound is possible which states that the potential enstrophy of the nonzonal flow cannot exceed ϵβ2, where ϵ = (U − Ucrit)/Ucrit is the (relative) supereriticality. This upper bound turns out to be extremely similar to the maximum predicted by the weakly nonlinear theory. For unforced flow with ϵ < 1, the bound demonstrates that the nonzonal flow cannot contain all of the potential enstrophy in the system; hence in this range of initial supercriticality the total flow must remain, in a certain sense, “close” to a zonal state.