You may encounter the following message you try to format with DiskPart a FAT32 partition bigger than 32 Gb.
This happens typically when you want to create a bootable USB key, and because nowadays most of the USB keys have a capacity greater than 32 Gb.
An easy way to fix this is to shrink the partition before you format it.
But first ensure the partition selected is really the one you want to shrink.
The basic command to shrink is the following
For example, if you want to shrink of one gigabyte
In DiskPart you can type help shrink to get more details on available parameters.
And here is a complete sequence provided as an example.