Wayne Barrow, the former manager of The Notorious B.I.G., has scored a legal win in his fight with the late rapper’s widow, Faith Evans, over money connected to Biggie’s music catalog and intellectual property.
Inside the Court Battle
On Aug. 7, a Delaware Chancery Court judge ruled that Barrow, who serves as trustee of the estate of Voletta Wallace, Biggie’s mother, and executor of her estate, is entitled to receive her share of distributions from a deal involving the late rapper’s catalog.
The ruling is due to the structure of Notorious B.I.G. LLC, the company formed by Voletta and Evans to manage the rapper’s intellectual property following his 1997 death. B.I.G. was shot and killed in a drive-by shooting in Los Angeles.
Before her death in February 2025, Voletta amended her trust and replaced her grandson, C.J. Wallace, Biggie and Evans’ son, with Barrow as sole trustee.
Barrow later tried to officially take control of the money and ownership rights that belonged to Voletta’s trust. Evans allegedly refused to hand over the money that Barrow said the trust was entitled to receive. This led to the lawsuit.
Judge Kathaleen McCormick, the Chancellor of the Delaware Court of Chancery, ruled in Barrow’s favor, finding that the trust was entitled to the rights and distributions associated with Voletta’s interest in the company. The judge also dismissed Evans’ counterclaim.
Evans filed a counterclaim arguing that Barrow did not have a formal position with Notorious B.I.G. LLC and that his attempt to take control of the company violated the LLC’s operating agreement.
Under the company’s operating agreement, Voletta and Evans each transferred half of their distribution rights to Biggie’s children, Ty’anna Wallace and C.J. That left Voletta, Evans, Ty’anna, and C.J. each entitled to 25% of company payouts.
The current ruling means Barrow, acting as trustee, is entitled to Voletta’s 25 percent share of distributions from the company’s partnership with Primary Wave. Primary Wave entered into a 50-50 partnership involving Biggie’s catalog and intellectual property in March 2025, shortly after Voletta’s death. The value of the deal has been reported at as much as $200 million.
McCormick’s ruling even invoked one of Biggie’s own lyrics. The opinion says: “In the song ‘Ten Crack Commandments’ from The Notorious B.I.G.’s posthumously released ‘Life After Death’ album, Christopher Wallace presciently cautioned: ‘Keep your family and business completely separated.’”
Barrow’s attorney Jay W. Freiberg called the ruling “a total victory,” saying his client now has the authority to carry out Voletta’s wishes concerning Biggie’s legacy.
The legal fight, however, is not over.
C.J. Wallace filed a separate lawsuit in Pennsylvania in February 2026 challenging Barrow’s authority as trustee and executor. The suit alleges Barrow improperly influenced Voletta before her death. That case remains pending.
