Habitable zones have usually been defined in terms of surface temperature, however over half of Earth's biomass is from subsurface microbes, and the temperature increases with depth, so the subsurface can be conducive for microbial life when the surface is frozen and if this is considered, the habitable zone extends much further from the star, even rogue planets could have liquid water at sufficient depths underground. In an earlier era of the universe the temperature of the cosmic microwave background would have allowed any rocky planets that existed to have liquid water on their surface regardless of their distance from a star. Jupiter-like planets might not be habitable, but they could have habitable moons.