  We consider the energy spectrum of a quasi-geostrophic model of forced,
rotating turbulent flow. We provide a rigorous a priori bound E(k) <= Ck^{-2}
valid for wave numbers that are smaller than a wave number associated to the
forcing injection scale. This upper bound separates this spectrum from the
Kolmogorov-Kraichnan k^{-{5/3}} energy spectrum that is expected in a
two-dimensional Navier-Stokes inverse cascade. Our bound provides theoretical
support for the k^{-2} spectrum observed in recent experiments.
