Spinodal decomposition occurs when a homogenous phase becomes thermodynamically unstable. An unstable phase lies at a maximum in free energy. In contrast, nucleation and growth occur when a homogenous phase becomes metastable. That is, another biphasic system becomes lower in free energy, but the homogenous phase remains at a local minimum in free energy, and so is resistant to small fluctuations. J. Willard Gibbs described two criteria for a metastable phase: that it must remain stable against a small change over a large area.