It does matter if he meant to or not, because if he chooses randomly from the remaining doors, the probability of him revealing a goat depends on whether you ha

It does matter if he meant to or not, because if he chooses randomly from the remaining doors, the probability of him revealing a goat depends on whether you have already chosen the car. Whereas if you know he could only ever reveal a goat, then the fact that he revealed a goat tells you nothing about your current selection. If you are interested in more details, Wikipedia lists this as the "Ignorant Monty" variant.