In my opinion, the first useless SW figure was Spirit of Obi-Wan Kenobi. Because it wasn't poseable at all. And you had to buy potato chips to send off for it.
Yet...it had its defenders. The old "he doesn't do anything in the films but stand there" crowd. I guess they forgot the scene where he sits down....yes, a ghost sits down.
I never got the Jedi Spirits cinema scene because of that.
It's subjective. There's deluxe figures that useless outside of their intention, like the ones with magnets on their feet. Or those ROTS "driver" figures that were permenently seated.