We use photoluminescence to study the time-average energy distribution of electrons in the presence of strong steady-state drive at terahertz (THz) frequencies, in a modulation-doped 125 Å AlGaAs/GaAs square well that is held at low lattice temperature TL. We find that the energy distribution can be characterized by an effective electron temperature, Te(≳TL), that agrees well with values estimated from the THz-illuminated, dc conductivity. This agreement indicates that under strong THz drive, LO phonon scattering dominates both energy and momentum relaxation; that the carrier distribution maintains a heated, thermal form; and that phonon drift effects are negligible.