Garmin Express running on the latest Windows 10 64 bit O/S would not update my NUVI 1250T w/4 GB SD formatted FAT, which updated fine in March. I copied the files and folders to a hard drive folder just in case I wanted to go back. Then I did a quick format to FAT32, and retried, and it updated OK. So, either Garmin Express PC hates FAT (demands FAT32) or requires an empty disk.
Someone with a FAT SD try emptying the disk first, so we can narrow it down!
Online help says FAT is OK! https://support.garmin.com/support/searchSupport/case.faces?caseId=%7B7d3c74d0-6b61-11e2-65d0-000000000000%7D => support.garmin.com/.../case.faces Someone should update that, if FAT32 is needed, and also update Garmin Express to actually express what is bothering it!