Maybe, sure. I wouldn't rule it out, but anyone trying such a thing would have to know it would be short lived. DB produced that outfit pretty quickly, and unless, as another poster suggested, she had purchased it in multiple sizes, (I've done that myself! When I've really loved a baby dress, I've bought two.) that would quickly squelch the idea that it was hers. So, it wouldn't lead the trail astray for long.
Another theory
a second guessing, the second guessing possibility (reminds me of the Iocane powder in The Princess Bride) is that the guilty party wanted it to look as though someone else was planting a red herring
which would seem to point guilt away from the household, because they themselves are the very ones who disproved it, by producing the dress.
That may be confusing. This is what I mean: MOO: Deborah plants a similar dress in the woods, knowing it will be found. Then she produces the original dress to discredit the very dress she herself planted. Then she can still say, "ah ha! Look! Someone is trying to throw us off the trail." kind of circuitous, but
maybe.