Delaware Court Rules Trust is Member of Notorious B.I.G., LLC

A Delaware court has ruled that the Voletta Wallace Revocable Trust is a member of Notorious B.I.G., LLC, which manages the intellectual property of the late rapper Christopher Wallace, known as The Notorious B.I.G. This decision affects the late rapper's estate and the distribution of his assets, particularly in light of ongoing disputes between his widow, Faith Evans, and his mother’s estate.

The ruling came from the Court of Chancery of Delaware on August 7, 2026, in case number C.A. No. 2025-0760-KSJM. The court's decision grants a motion for summary judgment filed by Wayne Barrow, the trustee of the trust, and dismisses a counterclaim from Evans, who argued against the trust's membership in the LLC.

Background

The parties involved in this case are Wayne Barrow, acting as the trustee of the Voletta Wallace Revocable Trust, and Faith Evans, the widow of Christopher Wallace. The dispute arose after Voletta Wallace, the rapper's mother, passed away in 2025 and left her interest in Notorious B.I.G., LLC to the trust. Just weeks before her death, she amended the trust to name Barrow as the sole trustee, removing her grandson from the position.

Following Voletta's death, Evans, who became the sole manager of the LLC, stopped making distributions to the trust, claiming that the LLC Agreement prohibited the transfer of membership units to the trust. Barrow filed the lawsuit on July 2, 2025, seeking declarations that the trust is a member of the LLC and entitled to distributions from it.

The Ruling

The court ruled in favor of Barrow, stating that the trust is indeed a member of Notorious B.I.G., LLC. The judge noted, "The Trust has demonstrated that it is a Permitted Transferee," and that the trust executed an instrument that was "reasonably satisfactory to the Manager." This ruling was based on the interpretation of the LLC Agreement, which the court found to be unambiguous regarding the trust's rights.

The court also dismissed Evans's counterclaim, which sought a declaration that the trust was not a member of the LLC. The judge emphasized that the trust had met the requirements set forth in the LLC Agreement for membership, thus reinforcing the trust's position in the management of the rapper's intellectual property.

Impact

This ruling has significant implications for the management of Christopher Wallace's estate and the distribution of his intellectual property rights. The decision confirms that the Voletta Wallace Revocable Trust is a legitimate member of the LLC, which means it is entitled to distributions and governance rights within the company. This outcome may influence how similar cases are handled in the future, particularly those involving trusts and LLC agreements.

Furthermore, this ruling clarifies the interpretation of membership rights in LLCs under Delaware law, particularly regarding the transfer of interests to trusts. It sets a precedent that could impact future disputes involving family estates and the management of intellectual property.

What's Next

While the court's ruling is final, it is possible that Evans may seek to appeal the decision. Additionally, there is a related case pending in Pennsylvania Orphans’ Court, where Christopher Wallace's son, CJ, is challenging the validity of the trust amendment and Barrow's position as trustee. This ongoing litigation could further complicate the management of the estate.