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| A Delaware Court of Chancery opinion issued Aug. 7, 2026, opens with a reference to the Notorious B.I.G.’s “Ten Crack Commandments” before ruling for Wayne Barrow on claims involving the Voletta Wallace trust’s membership and distributions from Notorious B.I.G., LLC. (Delaware Court of Chancery) |
The Notorious B.I.G.’s famous warning about mixing family and business has found its way into a Delaware courtroom, this time in a fight over the company created to protect his legacy.
A Delaware judge has ruled that a trust established by Biggie’s late mother, Voletta Wallace, is a full member of Notorious B.I.G., LLC, handing the rapper’s former manager Wayne Barrow a significantvictory in his dispute with Biggie’s widow, Faith Evans.
Chancellor Kathaleen St. J. McCormick granted partial summary judgment Friday, Aug. 7, in favor of Barrow, who is the sole trustee of the Voletta Wallace Revocable Trust. The ruling also dismissed a
counterclaim by Evans and the company that sought a declaration that the trust was not a member.
That distinction carries real financial consequences. McCormick ruled that the trust qualifies as a permitted transferee under the company’s operating agreement and is entitled to the membership and distribution rights that belonged to Voletta Wallace.
The judge opened her 16-page opinion by invoking Biggie’s 1997 song “Ten Crack Commandments” and its warning against mixing relatives and business. She then noted that Wallace and Evans ultimately did exactly that when they formed Notorious B.I.G., LLC in 2007 to manage intellectual property belonging to Christopher Wallace, better known as Biggie Smalls.
The structure behind the dispute is more complicated than a simple fight over who “owns Biggie.”
Voletta Wallace and Evans each held 50% of the membership units in Notorious B.I.G., LLC under a 2023 operating agreement. Each also assigned half of her distribution interest to one of Biggie’s children — Ty’anna Wallace and Christopher Jordan “C.J.” Wallace. The arrangement left Voletta, Evans, Ty’anna and C.J. each entitled to 25% of company distributions, according to the court.
The agreement specifically listed the Voletta Wallace Revocable Trust as a party permitted to receive membership units.
That became crucial after Voletta Wallace amended her estate documents Feb. 6, 2025, just weeks before her death. The amendment removed C.J. Wallace and longtime friend Carol Sampson as successor trustees and left Barrow as the trust’s sole successor trustee. A related change to Wallace’s will made Barrow the sole executor of her estate.
Wallace died Feb. 21, 2025. Barrow formally accepted his appointment as trustee the following month.
Evans then became the sole manager of Notorious B.I.G., LLC. According to the court record, she stopped making distributions to the trust and disputed whether the trust remained a member of the company after Wallace’s amendments.
Barrow sued in Delaware Chancery Court in July 2025.
At the center of the case was a seemingly technical question with large consequences: Did changing the terms and trustees of Voletta Wallace’s trust transform it into something different from the trust specifically named in the company agreement?
McCormick said no.
The judge found that amending a trust does not create an entirely new legal entity. Because the same Voletta Wallace Revocable Trust remained in existence, it remained a permitted transferee under the LLC agreement.
The court also rejected Evans’ objection to a written consent Barrow signed in December 2025 assuming Wallace’s rights and obligations under the company agreement.
The operating agreement required such an instrument to be “reasonably satisfactory” to the company manager. McCormick found that Barrow’s consent met that standard objectively, regardless of whether Evans personally approved it.
The ruling, therefore, grants Barrow summary judgment on his claims that the trust is a member of Notorious B.I.G., LLC and is entitled to distributions.
Barrow’s attorney, Jay W. Freiberg, called the decision “a total victory in a dispute that never should have happened” in a statement to Rolling Stone. He said Wallace wanted Barrow to help steward her son’s legacy after her death.
An attorney for Evans did not immediately respond to a request for comment from People following the ruling.
The stakes surrounding Biggie’s intellectual property have increased substantially in recent years.
In March 2025, Primary Wave Music announced a partnership with the Notorious B.I.G. estate. The Wall Street Journal reported that Primary Wave acquired a 50% interest in an estate valued at more than $200 million. Primary Wave has since described its relationship with the estate as encompassing publishing, master recordings, film and television rights, name and likeness rights, brand management and archival material.
The Delaware decision does not, however, end every dispute over Wallace’s estate plan.
C.J. Wallace filed a separate case in Pennsylvania Orphans’ Court in February challenging his grandmother’s decision to remove him as a trustee and executor. His petition alleges that Barrow exerted undue influence over Voletta Wallace and had conflicts with her heirs. Those allegations have not been decided.
Evans and Notorious B.I.G., LLC had asked McCormick to put the Delaware case on hold until the Pennsylvania challenge was resolved. She refused, finding that Barrow currently has legal authority to act for the trust unless a Pennsylvania court orders otherwise.
McCormick also stressed that the Pennsylvania case does not change the separate Delaware question of whether the trust itself is a member of Notorious B.I.G., LLC. Under both versions of Voletta Wallace’s estate plan, her membership units passed into the trust.
That makes Friday’s ruling important but narrower than some headlines about the dispute suggest.
It does not decide C.J. Wallace’s allegations about the circumstances surrounding his grandmother’s final estate changes. Nor does it hand Barrow sole control of Biggie’s catalog; Evans remains manager of the LLC.
What it does establish is that the Voletta Wallace trust cannot simply be treated as an outsider to the company. It has membership rights, and it is entitled to its distributions.
The agreement specifically listed the Voletta Wallace Revocable Trust as a party permitted to receive membership units.
That became crucial after Voletta Wallace amended her estate documents Feb. 6, 2025, just weeks before her death. The amendment removed C.J. Wallace and longtime friend Carol Sampson as successor trustees and left Barrow as the trust’s sole successor trustee. A related change to Wallace’s will made Barrow the sole executor of her estate.
Wallace died Feb. 21, 2025. Barrow formally accepted his appointment as trustee the following month.
Evans then became the sole manager of Notorious B.I.G., LLC. According to the court record, she stopped making distributions to the trust and disputed whether the trust remained a member of the company after Wallace’s amendments.
Barrow sued in Delaware Chancery Court in July 2025.
At the center of the case was a seemingly technical question with large consequences: Did changing the terms and trustees of Voletta Wallace’s trust transform it into something different from the trust specifically named in the company agreement?
McCormick said no.
The judge found that amending a trust does not create an entirely new legal entity. Because the same Voletta Wallace Revocable Trust remained in existence, it remained a permitted transferee under the LLC agreement.
The court also rejected Evans’ objection to a written consent Barrow signed in December 2025 assuming Wallace’s rights and obligations under the company agreement.
The operating agreement required such an instrument to be “reasonably satisfactory” to the company manager. McCormick found that Barrow’s consent met that standard objectively, regardless of whether Evans personally approved it.
The ruling, therefore, grants Barrow summary judgment on his claims that the trust is a member of Notorious B.I.G., LLC and is entitled to distributions.
Barrow’s attorney, Jay W. Freiberg, called the decision “a total victory in a dispute that never should have happened” in a statement to Rolling Stone. He said Wallace wanted Barrow to help steward her son’s legacy after her death.
An attorney for Evans did not immediately respond to a request for comment from People following the ruling.
The stakes surrounding Biggie’s intellectual property have increased substantially in recent years.
In March 2025, Primary Wave Music announced a partnership with the Notorious B.I.G. estate. The Wall Street Journal reported that Primary Wave acquired a 50% interest in an estate valued at more than $200 million. Primary Wave has since described its relationship with the estate as encompassing publishing, master recordings, film and television rights, name and likeness rights, brand management and archival material.
The Delaware decision does not, however, end every dispute over Wallace’s estate plan.
C.J. Wallace filed a separate case in Pennsylvania Orphans’ Court in February challenging his grandmother’s decision to remove him as a trustee and executor. His petition alleges that Barrow exerted undue influence over Voletta Wallace and had conflicts with her heirs. Those allegations have not been decided.
Evans and Notorious B.I.G., LLC had asked McCormick to put the Delaware case on hold until the Pennsylvania challenge was resolved. She refused, finding that Barrow currently has legal authority to act for the trust unless a Pennsylvania court orders otherwise.
McCormick also stressed that the Pennsylvania case does not change the separate Delaware question of whether the trust itself is a member of Notorious B.I.G., LLC. Under both versions of Voletta Wallace’s estate plan, her membership units passed into the trust.
That makes Friday’s ruling important but narrower than some headlines about the dispute suggest.
It does not decide C.J. Wallace’s allegations about the circumstances surrounding his grandmother’s final estate changes. Nor does it hand Barrow sole control of Biggie’s catalog; Evans remains manager of the LLC.
What it does establish is that the Voletta Wallace trust cannot simply be treated as an outsider to the company. It has membership rights, and it is entitled to its distributions.
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