To answer your question, relative ease is a function, in part, of one's skills & resources, so, it's certainly a reasonable claim to make, but will be different person to person.
Sure a little bit more involved than the two second AI prompt, but 3 min job for the lulz photoshoppers.
There are significantly more people able to type a few words into a prompt than people who can use an image editor fast and convincingly and would be inclined to waste their time on this kind of fake.
But would you? People grumble about $0.99 for an app they’ll use everyday, I doubt paying even $5 (and waiting for a result!) for a fake image to mislead police is high on anyone’s list.
Making this image was likely fast and free. It’s a crime of opportunity.
And there are literally billions of everyone else.
Do you not see that the amount of fake images has exploded with free access and ease of use? That’s what a tool does. It’s silly to argue generative AI doesn‘t make a difference in the proliferation of fake images, just like it’d be arguing that digital photography on a small multi-purpose device that is always with you doesn’t make people take more pictures.