FSP muses on whether papers with less citation means worthless paper (and, of course, concludes no):
My musings on this topic made me dive into my citation index to look at some of my low-citation papers to see if I could reasonably defend them as worthwhile in some way. My favorite example of a deservedly ignored paper in my oeuvre has surprised me by being cited in the low double-digits. Does that mean that the paper is more worthwhile than it was a few years ago because it has now received (slightly) more than 10 citations (none by me!) instead of 2 (or zero)? No, I don’t think so. The difference between 14 citations and 2 citations really isn’t that significant in terms of gauging the worth of a paper. And yet, although I am well aware that it was a fairly insignificant paper, I am reluctant to say it was a waste of time.
Further rummaging in my citation history shows me that some of my most highly cited papers do not represent what I consider to be my most significant work but that happened to be on topics that are of more widespread interest than the core of my research. Does that make these more-cited papers more “important” than my others? I am not objective about this, but I don’t believe that citations correlate with significance, though I admit that it depends on how you define “important” and “significance”.
One more personal example: A paper that has received a very modest number of citations is frequently mentioned to me as a paper that is read and discussed in graduate seminars. I am very pleased about that. The paper is being read and used (perhaps as an example of how not to write a paper..), although it is not cited very often. I consider that paper to have been worthwhile.
So, although I agree that zero citations is not a good thing for non-recent papers, and my papers have thus far avoided this fate (though in some cases not for any good reason), I have trouble casting aspersions on papers that have received a modest but non-zero number of citations.