A Delaware court handed the former manager of The Notorious B.I.G. a decisive win last week in a legal battle over the control of a nine-figure catalog deal built on the late rapper’s legacy.
On August 7, Delaware Chancellor Kathaleen McCormick ruled that Wayne Barrow, executor of Voletta Wallace's estate and trustee of her trust, is entitled to Voletta's 25% share of profits from the Primary Wave catalog partnership. That money, in turn, will go to the Christopher Wallace Memorial Foundation. Wallace, who died last February at 72 years old, was the mother of Biggie, real name Christopher Wallace.
The decision, which starts by quoting Big’s “Keep your family and business completely separated” lyric from “Ten Crack Commandments” (“After Wallace’s tragic death, however, his mother and widow did exactly the opposite,” McCormick notes), requires R&B vocalist Faith Evans, Biggie's widow and co-owner of Notorious B.I.G. LLC, to release the withheld funds to Barrow's trust. Evans was married to Biggie from 1994 to the time of his murder in March 1997. The couple share a son, CJ Wallace, 29.
The ruling confirmed that Barrow holds a 50% membership interest in the Notorious B.I.G. LLC intellectual property portfolio along with those 25% distribution rights. Evans countersued Barrow, contesting that the LLC's bylaws required her consent before any ownership transfer to him could take effect.
The dispute derives from the structure of Notorious B.I.G. LLC, a Delaware entity formed by Voletta and Evans to manage the rapper's intellectual property after his murder. Under the operating agreement, Wallace and Evans transferred half of their distribution rights to Biggie's children, leaving Voletta, Evans, Biggie’s daughter Ty'anna Wallace, and CJ Wallace each entitled to 25% of company payouts.
Primary Wave's acquisition of a stake in Biggie's catalog and certain name, image, and likeness rights closed in March 2025, shortly after Voletta's death. The Wall Street Journal reported the deal was valued at $100 million, now believed to be worth $200 million. Voletta had spent decades reclaiming catalog ownership from Bad Boy Records, ultimately securing full control before the Primary Wave partnership was struck.
Barrow sued Evans for seizing the catalog in July 2025, alleging she had distributed Primary Wave proceeds to Ty'anna and CJ while withholding the trust's share. The music executive sought the withheld funds and to replace Evans as company manager.
Barrow's attorney Jay Freiberg called the outcome "a complete vindication." "Faith had no basis whatsoever to withhold the money and to lock Wayne out," Freiberg told Billboard. "The judge in Delaware realized that and wrote a decision granting us full rights."
Another standstill hangs over the management of Biggie’s estate. CJ Wallace filed suit in Pennsylvania on February 20, 2026, alleging Barrow manipulated Voletta into granting him sole control of her estate. Voletta's trust had originally named CJ and Barrow as joint executors before being amended months before her death. The next phase of the legal dispute will take place in Pennsylvania, where CJ's claims against Barrow are still working through the courts.
