Life as we know and understand it requires three basic ingredients: energy, carbon and liquid water. Europa could have all three. Tidal flexing should heat the rocky mantle and lead to volcanism on Europa's ocean floor. At volcanic regions on Earth's ocean floors, water circulates through hot rock and emerges rich in chemical nutrients. Biological communities thrive at these warm oases. These oases do rely on a product of photosynthesis oxygen. Europan deep sea life could not depend on oxygen because their is no photosynthesis occuring on Europa. It is generally believed that Europan life has not extend past the microbial form. Then again life wasn't supposed to exist at hydrothermal vents either.
Photo of Europa Courtesy of NASA
Sources: Scientific America