Major League Baseball 2K9

Unless you're playing against another person and set this up, it's pretty difficult to be successful. One way is to max out Steal Aggression for every player on your opponent's team. Make sure their running speed is lowered in the Options menu inside the game. If you're lucky, they'll try to steal once you've pitched 2 strikes. It's a longshot but if this happens, immediately throw to the required base after pitching the final strike. You unlock this if you've struck out the batter and caught the runner stealing.

This can be done online, but I believe it cannot be done in an unranked game. I tried and it didn't unlock even though I struck out the batter and threw out the runner, who was stealing.