One of the Notorious B.I.G.’s former managers has won a legal battle against the late rapper’s widow, R&B singer Faith Evans, in the first of two lawsuits over proceeds from the sale of a stake in Biggie’s music catalog and management of his intellectual property assets.
A Delaware Chancery Court judge has sided with manager Wayne Barrow in a new ruling, finding that Evans had no right to withhold payments owed to a trust established by Voletta Wallace, the late mother of the music icon born Christopher Wallace. Barrow is the sole trustee of the trust and executor of Voletta’s estate.
After Voletta died in February 2025 at age 78, Evans rejected the trust’s request for payment, even though she and Voletta co-owned Notorious B.I.G. LLC, the company that controlled Biggie’s music catalog and likeness before it entered into a 50-50 partnership with Primary Wave in a landmark deal signed in March 2025.
Under the company’s operating agreement, Voletta and Evans each transferred half of their rights to company distributions to Biggie’s children, Ty’anna Wallace and Christopher Jordan “CJ” Wallace. That left Voletta, Evans, Ty’anna, and CJ each entitled to 25 percent of the company’s payouts.
The judge’s new ruling means Barrow, as trustee of Voletta’s trust, is entitled to receive her 25 percent share of distributions from the Primary Wave deal. According to court documents, the trust’s interest in the LLC will ultimately be distributed to the Christopher Wallace Memorial Foundation, the community nonprofit that Barrow helps lead as a board member.
In her new ruling obtained by Rolling Stone, the judge said Evans appeared to have been angered by Voletta’s decision, just weeks before her death, to amend her trust and remove CJ as a co-trustee. CJ is the son of Evans and Biggie.
“Presumably angered by the affront to her son, the defendant-widow took the position that the LLC agreement prohibited the transfer of membership units to the trust and refused to make distributions to the trust,” Chancellor Kathaleen St. J. McCormick wrote. She said that after reviewing the company’s operating agreement, she determined Voletta’s trustee was entitled to “any and all rights and obligations held by Ms. Wallace under the [company] agreement.”
A separate lawsuit filed by CJ in Pennsylvania challenges Barrow’s underlying authority as trustee and executor of Voletta’s estate. It alleges Barrow improperly influenced Voletta to place him in those roles shortly before her death. That case, filed on Feb. 20, 2026, remains pending.
“Wayne is feeling vindicated. We obtained a total victory in a dispute that never should have happened,” Barrow’s lawyer Jay W. Freiberg tells Rolling Stone, referring to Judge McCormick’s Aug. 7 opinion. “Wayne goes back with the family for decades, and Mama Wallace wanted Wayne to steward the legacy of the Notorious B.I.G. after she was gone, and he now will be able to do that. He knows it’s a very important task, and he’s looking forward to fulfilling Mama Wallace’s wishes in that regard.”
Freiberg and his co-counsel, Yelena Rapoport, declined to comment on the Pennsylvania-based lawsuit, saying it was still “in the early stages.” They did, however, accuse CJ of filing the Pennsylvania complaint to put the Delaware LLC dispute on hold. “That gambit failed,” Freiberg said.
Lawyers and representatives for Evans and CJ did not immediately respond to requests for comment on Monday.
In her 16-page ruling, Judge McCormick quoted from Biggie’s 1997 song, “Ten Crack Commandments,” which was included on his posthumously released album, Life After Death.
“Christopher Wallace presciently cautioned: ‘Keep your family and business completely separated,’” she wrote. “After Wallace’s tragic death, however, his mother and widow did exactly the opposite — forming Notorious B.I.G., LLC under Delaware law to manage the late rapper’s intellectual property. This litigation was perhaps the inevitable result.”
When Barrow initially sued Evans in July 2025, he said it was Voletta who negotiated and approved the “transformative deal” with Primary Wave that closed in March 2025, shortly after her death. According to The Wall Street Journal, the deal valued Biggie’s personal estate at $200 million.
Even before the Primary Wave deal was announced, interest in Biggie’s music remained steady for decades. Greatest Hits, a compilation released a decade after his murder in 1997, has now spent 401 weeks on the Billboard album chart.
Duane “Keffe D” Davis in District Court in 2025 in Las Vegas. AP Photo/John Locher, Pool
