I'm pretty sure what's being alleged is that there is real data exfiltrated from his devices on the laptop, but the laptop itself wasn't his. As in he was hacked, someone created the laptop with that data and added manipulations to it, then coincidently dropped it off to be "found".
Given the lack of proper chain of custody, it's probably likely.
Lol at mobile autocorrect, I wanted to say exfiltrated.