Intense tidal heating within Io produces active volcanism on the surface, and its internal structure has long been a subject of debate. A recent reanalysis of the Galileo magnetometer data suggested the presence of a high-melt-fraction layer with >50 km thickness in the subsurface region of Io. Whether this layer is a “magmatic sponge” with interconnected solid or a rheologically liquid “magma ocean” would alter the distribution of tidal heating and would also influence the interpretation of various observations. To this end, we explore the steady state of a magmatic sponge and estimate the amount of internal heating necessary to sustain such a layer with a high degree of melting. Our results show that the rate of tidal dissipation within Io is insufficient to sustain a partial-melt layer of ϕ > 0.2 for a wide range of parameters, suggesting that such a layer would swiftly separate into two phases. Unless melt and/or solid viscosities are at the higher end of the estimated range, a magmatic sponge would be unstable, and thus a high-melt-fraction layer suggested in Khurana et al. is likely to be a subsurface magma ocean.