I am not sure if that rule holds water and what people have against Star Trek III?
I don't recall the "Curse of the odd-numbered films" being mooted until ST V came out. Sure, some people had been disappointed that TMP was not the Trek they were expecting after such a long wait, but ST III was quite appreciated in its day. Suddenly, to gripe about ST V, fans and reviewers were saying that the even-numbered films (II and IV) were the "popular"/"good" ones.
But yeah, then "Nemesis" tossed that ol' rule away.
People didn't really start bringing this up until STV.