Jerusalem had many rock-cut tombs and the women visited at dawn in distress. Confusion is plausible, and saying opponents could have produced the body assumes anyone cared enough to look.

The Gospels say the women watched the burial and knew the location, and Joseph of Arimathea, who owned the tomb, knew where he had put the body. But grant the confusion anyway. The theory explains only an empty tomb, not appearances to individuals and groups, not Paul, not James. And the authorities did care: they had executed Jesus to end a movement that within weeks was announcing his resurrection in their own city. Walking to the right tomb was the cheapest refutation available.