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Here's a blueprint discussing this:

https://blueprints.launchpad.net/nova/+spec/no-downward-resize

The most relevant part:

Resize to a smaller disk can never work if the user already has more data than the new flavor allows - so for consistency any resize to a smaller flavour should be treated as an error.

The question is... will it let you do it via the API -- Maybe, but it should give you an error if it fails. This also may depend on the Hypervisor type and specific configuration options in nova.conf.

More helpful information:

https://bugs.launchpad.net/nova/+bug/1163844