"The holding of any person to service or labor under the system known as peonage is abolished and forever prohibited in any Territory or State of the United States; and all acts, laws, resolutions, orders, regulations, or usages of any Territory or State, which have heretofore established, maintained, or enforced, or by virtue of which any attempt shall hereafter be made to establish, maintain, or enforce, directly or indirectly, the voluntary or involuntary service or labor of any persons as peons, in liquidation of any debt or obligation, or otherwise, are declared null and void."[1]
As you can see, the reference is to "the system known as peonage". So, new, innovative means of accomplishing the same result may or may not be covered. So far, cases involving training repayment agreements do not seem to have taken the peonage route.[2]
The PetSmart case in California makes several arguments. One is that PetSmart is illegally operating an unlicensed educational institution. The "California Education Code provides that “a note, instrument, or other evidence of indebtedness relating to payment for an educational program is not enforceable by an institution unless, at the time of execution . . . the institution held an approval to operate.” (Cal. Educ. Code § 94917") There are other specific California labor laws probably being violated here. This case is just starting in San Mateo County Superior Court. Scheduling hearing in November.
But that won't help in other states with weaker labor laws.
[1] https://www.law.cornell.edu/uscode/text/42/1994
[2] https://towardsjustice.org/wp-content/uploads/2022/07/PetSma...