Pfsync in FreeBSD 10.0++ causes crashes when trying to synchronize states between two firewalls. The panic here is reached http://fxr.watson.org/fxr/source/netpfil/pf/if_pfsync.c?v=FREEBSD10#L1779 due to not found defer state after pf(4) itself defered a state. Reference: https://redmine.pfsense.org/issues/4310 Primary root cause of the crashes seems to be the defer option of pfsync which defers states on pf(4) to be treated by pfsync after. This is on as default on FreeBSD which should not be since active-active is not supported.
Closing as (a) 10 is no longer supported and (b) the pfsense issue appears to be solved, so it is assumed that the problem is fixed in FreeBSD as well.