no it doesn't - the tactical factor says that there has to be an element or terrain alrady in contact with the element's rear edge that would prevent it recoiling, and this is not the case in hte example you give - there is no element in contact with the target's rear edge.
Of course you might think that in this particular case any element in contact at all that prevents a recoil should trigger it...and I would tend to agree....but that's not what it says.....
Simply not being able to recoil is not enough to trigger the -1