Well, what's the real criteria here then? B/c as far as blocking, composition, visual storytelling, how to 'direct' actors, etc. Breen has none of that going for him. The 'it's so bad it's good' criteria (which I find a bit dubious with his first film) is something to consider for entertainment purposes; however, being notoriously bad would still net you in the 'worst' category.
But, he does entertain his audience. Sure, not in the way he hoped to. Plus, I'd give it to Uwe Boll just for the fact that his movies were mainly a tax scam.