Yes, except you'd need to get your target to install the Tile app and use it frequently enough that it keeps background location privs.
If Apple does come out with a cheap Tile-type device with a then this could be a legit concern. If you hid one in a person's belongings then you'd get hits from their phone- and turning it off wouldn't work, because random passersby would report their location as well.
This could even be better (worse) than spy-gear standalone GPS trackers because the battery would last for a very long time.