Yes, you can build pressure with engine off, for this reason. If a loader arm was in the max up position, the weight of the metal that the cylinder controls, is acting like a pump, and will try and push the fluid somewhere. It will probably push it through the valve until the cylinder has depleted all it's fluid. The lift arms on my Power, if left up at engine shut down, by the next morning , the arms are on the ground. Also, if there is an accumulator in a circuit, you can have some stored hydraulic fluid under pressure, and this could be dangerous if someone activated a circuit just by playing around. Pilot operated load checks will prevent the leak down in most cases. I believe that most loader valves will leak to some degree, some more than others. Otherwise, quality control. .