I get what you're saying but it's not like they picked him out of the stands and he hit a 61 yarder. He was still a professional kicker. If your definition of a fluke is "can't hit it consistently", than any 60 yarder by anyone not named Tucker would be a fluke. The word fluke has a lucky connotation and I don't think he was lucky.
I would call any 60 yarder a fluke the same way every Hail Mary is a fluke regardless of how good the QBs and WRs are.