Todd Mullins is managing partner of the Washington office and serves as chair of the Energy Enforcement practice group. He represents energy clients with enforcement and compliance matters involving the Federal Energy Regulatory Commission (FERC), the Commodity Futures Trading Commission (CFTC), the North American Electric Reliability Corporation (NERC) and other regulators, as well as related government and private litigation.
He co-led the development of McGuireWoods’ FERC Enforcement Reporter, an innovative, web-based legal research tool that organizes information about FERC enforcement cases and policy statements topically.
Prior to joining McGuireWoods, Todd was a branch chief at the Federal Energy Regulatory Commission’s Division of Investigations, Office of Enforcement in Washington, D.C., from 2006 to 2010.
There, he led cases and policy development for FERC under the Energy Policy Act of 2005, including market manipulation cases, electric reliability matters, general enforcement program matters, and developing FERC’s “Penalty Guidelines” that will have a significant impact on compliance programs and enforcement matters.
These all have significance under the “$1 million per violation, per day” civil penalty authority implemented under EPAct 2005. In private practice and in government, Todd has been involved in various forms of litigation and enforcement involving energy matters for more than 20 years.
- Representation of energy firms in CFTC and FERC trading investigations.
- Representation of multiple energy traders in several FERC investigations.
- Florida Blackout – FERC’s first investigation under the new Electric Reliability Standards; coordinated with NERC investigation. Resulted in then record $25 million settlement and substantial compliance requirements.
- Litigation in energy sector including actual trial experience – jury trial, bench trial, arbitration, and appeal. Included prosecution of numerous claims in some of the largest complex multiparty cases in the history of the nuclear power industry against a major vendor for defective equipment (e.g., Carolina Power & Light Corp. v. Westinghouse Electric Corp., 1990 R.I.C.O. Business Disputes Guide (CCH) 7494 (W.D. Pa. 1990).
- The George Washington University, JD, magna cum laude, Member, George Washington Law Review, 1989
- West Virginia University, BS, Finance, 1986
- District of Columbia
- U.S. District Court for the District of Columbia
- U.S. District Court for the District of Maryland
- Board Member, The George Washington University Energy Law Advisory Board (ELAB)
- Member, Antitrust, Public Utilities and Litigation Sections, American Bar Association
- Member, Compliance & Enforcement Committee, Energy Bar Association
- Capital Campaign Committee; Past Chairman, Congregational Council; Past Chairman, Board of Trustees; Past Chairman, Church Council, Foundry United Methodist Church
- Past Cubmaster; Past Committee Member, Cub Scout Pack 641, Boy Scouts of America
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