When Delaware Chancellor Kathaleen St. J. McCormick ruled in August on who belongs inside the company that holds the Notorious B.I.G.'s rights, she opened with a line from Life After Death. The double album came out 16 days after he was killed in 1997.

"Christopher Wallace presciently cautioned: 'Keep your family and business completely separated.'"

His mother and his widow had done the opposite, forming Notorious B.I.G., LLC together in 2007 to manage his intellectual property, and McCormick could see where that partnership had led once one of them died. "This litigation was perhaps the inevitable result," she wrote in a 16-page opinion.

Her October opinion attached a number to that result. On Tuesday (Oct 27), McCormick ordered Faith Evans, who has run the company alone since Voletta Wallace died on Feb. 21, 2025, to pay $12,518,336 to the Voletta Wallace Revocable Trust. The sum is the profit Wallace's 25 percent share earned between her death and the end of 2025. Wayne Barrow's attorney, Jay Freiberg, told Billboard that interest will push the total close to $14 million. Evans had argued the trust was owed $48,612, counting only from the day it was formally admitted as a member in December. McCormick ruled that the trust's claim to the money began the day Wallace died.

The Deal She Negotiated Closed After She Was Gone

Voletta Wallace spent close to three decades pulling her son's work back toward the family. Biggie reportedly died holding half of his publishing, with the rest at Sean Combs' Bad Boy. His mother pushed the estate's share to 85 percent in the early 2000s and bought out the last 15 percent in 2020. Ownership questions from the Bad Boy era still surface in other courtrooms, where a co-founder's claim to a quarter of the label is still pending in Manhattan federal court.

Her final negotiation was with Primary Wave, the New York publisher whose roster of late artists includes Whitney Houston, Prince, Luther Vandross and Isaac Hayes. Sources told The Wall Street Journal that she was involved in nearly every stage of the talks. The deal gave Primary Wave a 50 percent interest in the estate's publishing, recordings and name, image and likeness rights at a valuation above $200 million. Primary Wave confirmed the closing on March 20, 2025, 27 days after Wallace died.

The money from that closing flowed into Notorious B.I.G., LLC during exactly the stretch Evans would later say the trust had no claim to. Under the company's structure, as laid out in the October opinion, Evans and Wallace each held half of the membership. Distributions split four ways, a quarter apiece to Evans, to Wallace, and to each of Biggie's children, T'yanna Wallace and Christopher Jordan "CJ" Wallace. After Wallace's death, Evans became the sole manager and stopped sending Wallace's quarter to the trust.

How Delaware Separates a Seat From a Paycheck

Under Delaware law, where the company was organized, an LLC interest carries two separate bundles of rights, one covering votes and management and the other covering profits. Section 18-702 of the Delaware Limited Liability Company Act provides that a person who receives an interest is entitled to the distributions the original holder would have received. That person does not become a member or exercise a member's powers unless the company agreement or the remaining members allow it. A neighboring provision, Section 18-705, lets the personal representative of a member who dies exercise that member's rights in order to settle the estate.

The August ruling settled the first bundle. McCormick found that the operating agreement named the Voletta Wallace Revocable Trust as a permitted transferee, which meant Wallace's stake could pass to it. Barrow, as sole trustee, held "any and all rights and obligations held by Ms. Wallace under the [company] agreement." Weeks before her death, Wallace had amended the trust and removed her grandson CJ, Evans' son with Biggie, as a co-trustee, which left Barrow in control.

McCormick did not read the resistance that followed as a dispute over contract language alone. "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," she wrote. Freiberg told Rolling Stone after that ruling that his client felt cleared. "Wayne is feeling vindicated. We obtained a total victory in a dispute that never should have happened," he said.

The $48,612 Position

Winning membership left the second bundle open, and Evans built her last line of defense around the calendar. The trust was formally admitted as a member on Dec. 12, 2025, and Evans and the company argued that its share of the profits should be counted from that date forward. Counted that way, the trust's distributions for 2025 came to $48,612, a figure covering roughly the final three weeks of the year.

McCormick rejected the premise that the money waited on the paperwork. "All economic rights associated with Ms. Wallace's member interest in the LLC transferred to her estate upon her death," she wrote, in language quoted by Digital Music News. "The Trust, as the ultimate beneficiary, is entitled to distributions accrued as of the date of Ms. Wallace's death."

The gap between the two readings is $12,469,724. It covers the ten months in which the Primary Wave money landed, when distributions kept accruing in Wallace's name and nobody was sending them to the trust. The court also ordered interest compounded quarterly on everything that went unpaid, and Evans' attorney declined to comment to Billboard on the ruling.

The catalog kept earning through those months on its own steam as well. Greatest Hits, the compilation released a decade after Biggie's death, had logged 401 weeks on the Billboard 200 by this August, according to Rolling Stone.

The Foundation, the Grandson and the Pennsylvania Case

Under the terms of Wallace's will, the money is headed to the Christopher Wallace Memorial Foundation, the charity she established in her son's name. Who directs it once it arrives is the subject of a second lawsuit, filed in Pennsylvania on Feb. 20, 2026, by CJ Wallace.

CJ's petition challenges the amendments his grandmother signed 15 days before she died, which removed him and longtime family friend Carol Sampson from administrative roles and left Barrow as sole trustee and executor. CJ alleges that Barrow improperly influenced Wallace in her final weeks, and Barrow denies it. Barrow has also claimed that Evans is working with her son behind the scenes on that case, which her legal team denies.

Freiberg told Rolling Stone in August that the Pennsylvania filing had been aimed at putting the Delaware case on hold, and that McCormick's ruling ended the attempt. "That gambit failed," he said. In October, McCormick again found that the Pennsylvania proceedings did not stop the trust from collecting its distributions. Pennsylvania will decide who runs the trust, while Delaware has already decided what the trust is owed, whoever ends up holding the keys.

What Happens Next

Barrow has 20 days from the Oct. 27 ruling, a deadline that falls in mid-November, to submit a final proposed order reflecting McCormick's findings. Once the court enters a final order, Evans would have to pay or challenge it, and an appeal from the Court of Chancery would go to the Delaware Supreme Court. Her legal team has not said publicly whether she intends to take that step.

The company Wallace and Evans formed in 2007 still splits its distributions four ways and still shares the catalog with Primary Wave. The quarter that belonged to Wallace has been accruing in the trust's name since Feb. 21, 2025, and the interest on it compounds every three months it goes unpaid.