I'm not so sure about that...
I worked at a TV news station in a major city where police told us they could track cell phones that were turned off. IIRC, it came up during an interview after they apprehended a suspect in a big rape/murder case. The suspect's phone was off, but they were able to track him. They told us they didn't really want the public to know they could do this, but it seems it's too late for that [1].
I'm not sure what the limitations are-- whether it'll work if the battery is removed (maybe there's amother battery?) or whether it only works with certain phones.
[1] https://www.quora.com/Can-law-enforcement-track-someone-by-t...