Presumably, no one is going to try to prove something wrong that has already been proven wrong, so unless there are many obscure flaws in one's work that take multiple papers to uncover, it shouldn't affect the citation count much.
In introductions, papers often give a short overview of what's been done before, so early work in a field often gets cited even if it turns out to have been flawed. (It can't be completely ridiculous, of course, it must have sounded plausible at the time, but even shoddy research often does.)
