Before joining ACUS, Todd was a lawyer at the U.S. Department of Education, where he worked in the Office of the General Counsel on the department’s regulatory agenda. Todd advised various policy officials and lawyers in the department on all aspects of the rulemaking process. Additionally, Todd advised the Acting General Counsel on matters pertaining to oversight requests from congressional committees, the U.S. Government Accountability Office, and the Office of the Inspector General. Before coming to the department, Todd worked at the Bazelon Center for Mental Health Law where, among other responsibilities, he analyzed notices of proposed rulemaking pertaining to housing, education, and employment.