Ocular microtremor (OMT) is an involuntary fixational eye movement. We identify the implications of biospeckle for a noninvasive, laser speckle correlation technique to measure OMT. Biospeckle from the in-vivo eye is characterized and, using the resulting characteristics, a mathematical model to describe the biospeckle from the eye is designed and tested. Through in-vivo measurements, biospeckle is shown to disrupt the temporal stability of the speckle images over time. However, provided each speckle image is cross correlated with the previous image within a sufficiently short time, the stability of speckle images captured from the eye is shown to be adequate to measure OMT-like displacements.