 He held similar positions at the University of Macerata from 1972 to 1973 and the University of Salerno from 1973 to 1975.In 1975 he started as a professor of Public Law at the Sapienza University and later also held a chair in constitutional law.On 25 November, the Italian Parliament failed to elect three candidates to the Constitutional Court; Modugno obtained 140 votes, primarily coming from the Five Star Movement.