A toy photo, or photo of toys, you choose. But if it’s a toy photograph, it’s the earliest I’ve found so far. And if its simply a photo of toys, its still a pretty cool find.
In quoting myself from the third link below- “Toy Photography and the photography of toys are two very different things. Toy Photography is the photography of toys, miniatures, trinkets, in scenic environments to tell a story, or relay an idea. The photography of toys is simply that – straight forward photography of an item or group of items with the intention of showing off that item in itself, and not creating a larger idea around it.”
While there’s no information on what the person setting up this display was thinking, as it was from a doll show, it is likely that it is simply that, a display. And leaves this image to remain in the category of “photography of toys.”
Further, Benjamin West, largely known for his landscape stereoscopic images, would only have photographed the display and not have set it up. I wouldn’t say photographing an already set up scene removes the image from the definition of toy photography, but there needs to be evidence in lighting and framing that an attempt at a story or emotion was made.
Alternatively, check out the first link below for 1898 “toy photography.”