The Notorious B.I.G.’s former manager has won the first round in a messy legal battle over the late hip-hop legend’s lucrative music portfolio.
A Delaware judge ruled on Friday (Aug. 7) that Biggie’s mother, Voletta Wallace, legally named Wayne Barrow as the successor of her 50% stake in the rapper’s intellectual property assets before she died last year. This means Biggie’s widow Faith Evans, who controls the other half of the portfolio, must give Barrow access to Voletta’s 25% cut of the profits from a landmark Primary Wave catalog deal.
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Per Voletta’s will, Barrow will distribute her share of the Primary Wave money to the Christopher Wallace Memorial Foundation. The rest of the proceeds from the deal, valued at $100 million by the Wall Street Journal, are to be split evenly among Biggie’s two children, CJ and Ty’anna Wallace, and Evans.
Barrow’s attorney, Jay Freiberg, told Billboard on Monday (Aug. 10) that the court decision is “a complete vindication” in the lawsuit against Evans.
“Faith had no basis whatsoever to withhold the money and to lock Wayne out,” said Freiberg. “The judge in Delaware realized that and wrote a decision granting us full rights.”
Reps for Evans and Primary Wave did not immediately return requests for comment on the ruling.
The legal fight began a few months after Voletta’s February 2025 death at the age of 78. Voletta had named Barrow, who managed Biggie (born Christopher Wallace), as both the sole executor of her estate and the trustee who should control her interest in the business entity known as Notorious B.I.G. LLC.
Barrow sued Evans last July, alleging the R&B singer was refusing to recognize his ownership stake or share proceeds from the “transformative” Primary Wave deal that Voletta negotiated shortly before dying. In that deal, Primary Wave acquired a stake in Biggie’s catalog as well as certain name, image and likeness rights. Evans countersued, claiming that the LLC’s bylaws did not permit Voletta to transfer ownership to Barrow without her consent.
Delaware Chancellor Kathaleen McCormick sided with Barrow on Friday. The judge said Evans’ legal position “fails at many levels,” and that, per the language of the LLC contract, Barrow is entitled to both a 50% membership interest and 25% distribution rights for Biggie’s intellectual property portfolio.
In her ruling, Chancellor McCormick observed that the lawsuit was “perhaps the inevitable result” of Voletta and Evans’ decision to become 50-50 partners in Biggie’s music catalog after the rapper was killed in 1997: “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,’” wrote the judge. “After Wallace’s tragic death, however, his mother and widow did exactly the opposite.”
Still, the legal fight over Barrow’s role is not yet over. Biggie’s son CJ has his own lawsuit pending in Pennsylvania, alleging that Barrow manipulated Voletta into giving him complete control of her estate before she died. Voletta’s will originally named CJ and Barrow as joint executors, but it was amended a few months before her death to make Barrow the sole administrator. That Pennsylvania case is still in the early stages.
