I honestly got this without trying. I was playing this game for the first time in weeks, and I had pretty much given up on this level. IIRC, I was right in the middle when I picked it up. I know I didn't really move or swerve too much to get it. I never even saw it.
Most painful 360 games I've ever played for achievements: Beowulf, Golden Compass, Afro Samurai, Brave, Infernal, Cabela anything, Splosion Man, NFL Tour, Prison Break, Darkest of Days, NBA Ballers