Various moons around gas giants have maintained liquid water oceans despite getting zero sunlight. My assumption is that much of that is due to surface ice acting as an insulator. They also get heat from tidal forces, which doesn't let you cook things but does keep the ocean an ocean rather than an iceball:
As the above article notes, silicon dioxide particles believed to have originated from Enceladus would require temperatures close to boiling to have formed, which implies the liquid ocean probably has hydrothermals in additional to tidal forces. Overall though I'd agree that the various underground oceans can't support sapient or quite possibly even just complex life, due to the limited energy and resources available. That said I do wonder... what if you had a moon like Io that's getting practically pulled apart by larger moons and the gas giant it orbits, but has a composition more akin to iceballs like Europa?
This seems to imply that the factors that give Io so much tidal heating also probably denied it access to water (and other key ingredients for life like nitrogen and carbon dioxide) however it also indicates that the loss was because of Jupiter being hot not tidal forces so it isn't necessarily a dealbreaker.
So if could you end up with a tidally churned volcanic underground ocean world would that be able to support more advanced life? I mean you talk about sunlight giving more energy, but outside of climate/weather/temperature (which isn't applicable to underground oceans anyways) I'm pretty sure that life is only using a small fraction of the sunlight that hits anyways.