I think people tend to vote with their hearts rather than their heads (this isn't a criticism by the way as it just proves passion) when nominating 'worst' and 'best' is concerned. A lot of the time any technical merit can easily be overlooked if a film doesn't touch you in a way in which you like, and it's difficult to be objective in these cases.
As an example, I think The Birth of a Nation is a truly appalling film, but it is still an important and historical milestone in cinematic history and a technically well made piece of work. Therefore, despite my feelings towards it you'll never see it grace a 'worst of' film list from me.
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