Biggie Smalls Estate Legal Battle: Manager Wins Ruling Against Faith Evans

One of the Notorious B.I.G.’s former managers has secured a significant legal victory against the late rapper’s widow, Faith Evans, in the first of two lawsuits concerning proceeds from the sale of a stake in the legendary artist’s music catalog and intellectual property assets. A Delaware Chancery Court judge has sided with manager Wayne Barrow, ruling that Evans had no legal standing to withhold payments owed to a trust established by Voletta Wallace, the mother of the late Christopher Wallace.

Barrow, who serves as the sole trustee of the trust and executor of Voletta’s estate, successfully argued that the funds were improperly withheld. Following Voletta’s passing in February 2025 at the age of 78, Evans had rejected the trust’s request for payment. This conflict arose despite the fact that both women co-owned Notorious B.I.G. LLC, the entity that managed the rapper’s catalog and likeness prior to a 50-50 partnership deal with Primary Wave signed in March 2025.

The Legal Dispute Over Catalog Rights

Under the company’s operating agreement, Voletta Wallace and Faith Evans had each transferred half of their rights to company distributions to Biggie’s children, Ty’anna Wallace and Christopher Jordan “CJ” Wallace. This arrangement left Voletta, Evans, Ty’anna, and CJ each entitled to 25 percent of the company’s payouts. The recent court ruling confirms that Barrow, acting on behalf of Voletta’s trust, is entitled to her 25 percent share of the distributions from the Primary Wave deal. These funds are slated to be distributed to the Christopher Wallace Memorial Foundation, a community nonprofit that Barrow helps lead.

In her 16-page ruling, Chancellor Kathaleen St. J. McCormick noted that Evans appeared to be motivated by personal grievances, specifically Voletta’s decision to amend her trust and remove CJ—the son of Evans and Biggie—as a co-trustee shortly before her death. “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,” the judge wrote.

Lingering Legal Challenges

While this ruling provides clarity on the Delaware LLC dispute, a separate lawsuit filed by CJ in Pennsylvania remains pending. That case challenges Barrow’s authority as trustee and executor, alleging that he exerted improper influence over Voletta in her final days. Barrow’s legal team has dismissed the Pennsylvania filing as a strategic attempt to stall the Delaware proceedings, a tactic they claim has failed.

Reflecting on the court’s decision, Barrow’s attorney, Jay W. Freiberg, told Rolling Stone, “Wayne is feeling vindicated. We obtained a total victory in a dispute that never should have happened. 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.”

Judge McCormick concluded her ruling by referencing the rapper’s own lyrics from “Ten Crack Commandments,” noting that while Christopher Wallace famously advised keeping family and business separate, the formation of the LLC to manage his intellectual property made such a separation difficult to maintain. The Primary Wave deal, which reportedly valued the estate at $200 million, continues to be a focal point for the family’s ongoing legal and financial entanglements.