The objective of this study was to investigate the influence of the physical state of emulsified lipids on their in vitro digestibility by pancreatic lipase. A 10 wt % tripalmitin oil-in-water emulsion stabilized by sodium dodecyl sulfate (0.9 wt % SDS) was prepared at a temperature (>70 °C) above the melting point of the lipid phase (Tm ≈ 60 °C). A portion of this emulsion was cooled to a temperature (0 °C for 15 min) well below the crystallization temperature of the emulsified lipid (Tc ≈ 22 °C) and then warmed to 37 °C so as to have completely solid lipid particles. Another portion of the emulsion was directly cooled from 70 to 37 °C (which is above the Tc) to have completely liquid (supercooled) lipid particles. Pancreatic lipase (8 mg/mL) and bile extract (5.0 mg/mL) were then added to each emulsion at 37 °C, and the evolution of the particle charge, particle size, appearance, and free fatty acid release were measured over a period of 2 h. It was found that the rate and extent of lipid digestion were higher in the emulsion containing liquid particles but that appreciable lipid digestion still occurred in the emulsion containing solid particles (i.e., >35% lipid digestion after 2 h). These results may have important consequences for controlling the digestion rate of lipids or for developing solid lipid particle delivery systems for lipophilic functional components.