Theresa Peer sued Liberty Life over its denial of an ERISA disability benefit: a waiver of life-insurance premiums. After Peer filed suit, Liberty Life reinstated coverage and the waiver retroactively, mooting her claims. The district court later awarded Liberty Life fees for post-reinstatement litigation, charging Peer’s lawyer, Paul Sullivan, under ERISA’s fee-shifting provision. The Eleventh Circuit held that ERISA § 1132(g)(1) authorizes fee awards against parties, not their lawyers, and does not serve as a sanction for attorney misconduct. It therefore reversed and vacated the award against Sullivan. The court did not decide Liberty Life’s cross-appeal seeking fees from Peer. On remand, the district court could consider fees against Peer under ERISA or sanctions against Peer or Sullivan under another statute, procedural rule, or its inherent authority.