already commenced by or against members of the class; (C) The desirability or undesirability of concentrating the litigation of the claims in the particular forum; (D) The difficulties likely to be encountered in the management of class action. 5 . The Court cautioned, however, that the possibility that Congress meant military retirement pay to be current pay suggested that states “tread with caution in this area, lest they disrupt the federal scheme.” 453 U.S. at 224 n. 16, 101 S.Ct. at 2736-37 n. 16. 6 . Both Bohn v. Waddell, 164 Ariz. 74, 790 P.2d 772 (Ariz.Tax 1990), and Pledger v. Bosnick, 306 Ark. 45, 811 S.W.2d 286 (1991), held that, under Davis, tax schemes that discriminated against military retirees were unconstitutional. Cf. Barker v. State, 249 Kan. 186, 815 P.2d 46 (1991) (<HOLDING>). 7 . Under Chevron, a court is to consider
holding that retirement benefits are accrued benefits under erisa holding that an employees claim for breach of a letter agreement was preempted by erisa where the agreement did not specify the amount or other terms of the employees retirement benefits and the court would have to refer to the employers erisagoverned retirement plan to determine the employees retirement benefits and calculate the damages claimed holding that military retirement benefits are to be considered deferred pay for past services holding that military retirement benefits are current pay and thus significantly different than other retirement benefits holding that  disposable retirement pay  from military pension was equal to gross retirement pay less federal income taxes