The stability of shape fluctuations of a flat charged membrane immersed in
a fluid is analyzed using a linear stability analysis. A displacement of th
e membrane surface causes a fluctuation in the conterion density at the sur
face. This in turn causes an additional contribution to the force density i
n the momentum equation for the fluid, which results in a normal stress at
the surface which is opposite in direction to the stress caused by surface
tension. This electrohydrodynamic effect destabilizes fluctuations when the
surface potential exceeds a critical value.