Biofilm structure plays an important role in biofilm function and control. It is thus important to determine the extent to which mechanics may determine structure in biofilms. We consider a generic qualitative constitutive description of biofilm incorporating as assumptions a small number of fundamental physical properties of biofilm viscoelasticity and cohesion. Implications of cohesive energy on biofilm structure are then explored. Steady solutions and energy minima are studied and it is demonstrated that cohesion energy leads naturally to a free surface film state. It is found that in many circumstances, biofilms could be subject to heterogeneity formation via spinodal decomposition. Such material heterogeneity may have important implications for structural stability in biofilms both on short and long time scales.