The general rule of thumb is that life needs liquid water.. within that range, life has been found in Arctic areas and volcanic vents. Intelligent life (tool users) would require a more precise environment. A water world would likely prevent life from using fire, a key ingredient to advancing a society. Material for easily fashioning primitive tools is another. Imagine if plant life was only grass and moss. You couldn’t make a crude spear or axe.
I tend to take a different tack on intelligent life.
The last thing we need to find is intelligent life. We need life we can eat. As it is the vegans are already afraid we’ll be carnivores in space.