Every airplane obviously flies good enough for someone to have deemed them marketable, so I think that there is as many "worst" trainers as there are pilots. It's what you want out of this hobby that maks one trainer a "best" and another a "worst" trainer. If you hate building, don't have a lot of time, and take chances trying to learn quickly or go it on your own and would probably quit over a destructive whipe-out...an LT-40 kit would be a "worst" trainer for you. If you are a craftsman, enjoy building, are not impatient, have a good dedicated instructor, don't take chances and can't stand ugly airplanes...a DuraPlane may be your "worst" trainer.
I think that naming a "worst" trainer is either impossible or must be looked at on a pilot by pilot viewpoint. The absolute bottom line is that the "best" trainer for you is one that will keep you in the hobby and motovate you on to your next airplane...and your "worst" trainer is one that will give you a bad experience and make you find another hobby.
Along these lines, in my first year in the hobby I destroyed a SIG Colt, a Balsa USA Swizzle stick, A SIG Cadet, and then a Goldberg Falcon 56. I was in school 40 hours a week and was working full time. I was a "fair" pilot who didn't go to the field to fly the pattern all day...I wanted to get radical and have fun. I got a hold of something called a Lanier Comet. Took one afternoon to put it together...it was ugly, heavy, and flew like crap...but that plane got me to the field, and I put it through hell and it took the abuse. I went from hating a hobby that involved too may hours of building...to really having a ball with something that got me in the air dispite my lack of time and finances. At that time...a plane that many laughed at and called the worst thing to ever happen to the hobby...was actually the "best" plane for me at the time. Had it not been for that flying turd, I may be a golfer or something now