rS307825 and rS333017 disallow building FreeBSD-HEAD from 9.x or 10.x versions that have some clang issues.
Minimum supported SVN revisions and osreldates:
Version Min Rev osreldate 9.x r286035 903509 10.x r286033 1002501
9.3 is the final 9.x release and does not contain the rS286035 fix. 10.3 is the first 10.x release with the fix.
Although it may still be possible to build HEAD from an up-to-date stable/9 it's not worth maintaining the special case when the branch itself is unsupported and there are no usable releases from that branch.