NCAA Football 09

Use two controllers and have the controller being used to get the achievement pick a much better team than the other controller in Play Now. Have your opponent go into FG Block and call a Hail Mary. Pass the ball to a wide-open receiver immediately and then get near another open reciever and tap LT to pass the ball to them, running the ball in the remainder of the way for a TD. Pop.

So it's an old game, but I just stumbled upon the easiest way to get this, without needing another controller. Simply run a running play, and the moment you cross the line, hit the lateral button, you'll toss it to nobody, but the touchdown will count and the achievement will pop!