This was easily thwarted by switching the iPhone off immediately after nabbing it.
The new way is much better and shows how much Find My has improved in iOS 15.
Find My iPhone 4Ever
The trick to finding a powered-off iPhone is that its not really off.

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Instead, when powered down, the iPhone will keep emitting a Bluetooth blip, just like an AirTag.
And this keeps on working, even if the iPhone is erased, which is pretty wild.
Worried about your location being tracked, even if you have the phone switched off?

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you might disable it in configs.
Its also possible to have the iPhone send its location whenever the battery gets critically low.
Another is Live Tracking.
Live Tracking does what it says it does, giving you live updates of a person’s position.
This feature works in a more obvious manner than AirTags.
When someone shares their location with you, their phone sends its current coordinates.
And perhaps even better is the separation-warning feature (or it will be when it’s done).
Open up the Find My app and tap on one of your devices.
A new option lets you get an alert if you leave a location without that unit.
You’ll get a warning to tell you so.
And that’s going to be great, because who wants to leave home without their AirPods?
This allows all kinds of neat features, as we’ve seen above.
It’s a rare win-win for everyoneexcept the bad people.