Easily done right at the start of the game
Simply bump into a police car to get a 1 Star Wanted Level and drive into a Pay n Spray (Spray can icon on map/Radar) to wipe that Wanted Level and get the achievement, doesn't have to be done by bumping a police car, anything that can get Wanted Level will work as long as you use a Pay n Spray
Or, if you wait until the mission "Drive-By" you will get a Wanted Level that you HAVE to lose by using a Pay n Spray to finish the mission