I can certainly see a problem. With respect to the final validation stage, where the validator is communicating with the TLS endpoint, all the information needed to satisfy the validator is presented IN the SNI request data.
It looks like anyone could request a tls-sni-01 validation with any account key, for a host that they new would resolve to a TLS server infrastructure with a certain behavior and in turn be able to get the certificate issued.
The qualifying behavior would be a TLS server infrastructure which has some sort of opportunistic generation of a self-sign certificate for an unrecognized SNI name, such that the just-in-time minted certificate would have a single SAN dnsName being that exact value requested in the SNI. Unlike the other challenges where the final validating query from the VA does NOT contain the "answer" needed, it would appear that the in the final pass of the TLS-SNI-01 protocol exchange, the final "answer" is indeed in the request.
You know, I'm trying to recall the details, but I'm pretty sure I came across a consumer router platform once that, until and unless administratively configured with a certificate, would keep opportunistically recreating certificates to match the SNI name. This was to make the only validation failure be "signed by an untrusted..." instead of "name mismatch", etc, etc.... I wonder if a critical mass of things like that has arisen?