Energy limits that delineate the `habitable zone' for exoplanets depend on a given exoplanet's net planetary albedo (or `Bond albedo'). We here demonstrate that the planetary albedo of an observed exoplanet is limited by the above-cloud atmosphere - the region of the atmosphere that is probed in remote observation. We derive an analytic model to explore how the maximum planetary albedo depends on the above-cloud optical depth and scattering versus absorbing properties, even in the limit of a ...