Tenneco Oil Co. v. Kern Oil & Refining Co.

How later courts describe this case

• holding section 1821 applicable to fee-shifting provision of Equal Pay Act because "the broad language in Crawford Fitting does not permit a distinction based upon whether or not the award is made under a fee-shifting statute"
• in context of liquidated damages award arising under Equal Pay Act, court rejects discredited argument that market forces led defendant-employer to reasonable belief that discriminatory pay practices were in conformity with law
• new claims by plaintiff related back to original complaint filed against same defendant because amended claim arose out of original transaction or occurrence
• “[W]e have allowed a party to raise res judicata after the initial pleadings by construing the attempt as a motion to file a supplemental answer.... [W]e have always required that [res judicata] be raised before trial.”