For some searches SEO has died. Even if you get #1 rank, your still pushed down below the fold near the bottom of the page. So in this sense, absolutely. It does very little good in some cases to achieve top 5 rankings. This is clearly by design as we have seen a gradual move to push organic searches off page 1.
The worse results google delivers, the more adwords revenues increase, as these will be the only relevant results. I just ran a query and the #1 result is a page full of viri and exploits. this is for a product keyword. "User experience," yeah right google!
I would love to post the keyword here. Mods let me know if it would be allowed. The serps a real joke these days.