Wayne Barrow, as Trustee of the Voletta Wallace Revocable Trust v. Faith Evans

Court of Chancery of Delaware·Decided August 7, 2026·No. C.A. No. 2025-0760-KSJM·Published

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

WAYNE BARROW, as Trustee of ) the VOLETTA WALLACE ) REVOCABLE TRUST, ) ) Plaintiff/Counterclaim ) Defendant, ) ) v. ) C.A. No. 2025-0760-KSJM ) FAITH EVANS, ) ) Defendant. ) ) and ) ) NOTORIOUS B.I.G., LLC, ) ) Nominal Defendant/ ) Counterclaim Plaintiff. )

MEMORANDUM OPINION

Date Submitted: May 11, 2026 Date Decided: August 7, 2026

Scott B. Czerwonka, WILKS LAW, LLC, Wilmington, Delaware; Jay W. Freiberg, Yelena Rapoport, ELMAN FREIBERG PLLC, New York, New York; Counsel for Plaintiff/Counterclaim Defendant Wayne Barrow, as Trustee of the Voletta Wallace Revocable Trust.

Seth A. Niederman, Kasey H. DeSantis, FOX ROTHSCHILD LLP, Wilmington, Delaware; Lawrence C. Hinkle II, SANDERS ROBERTS LLP, Los Angeles, California; Counsel for Defendant Faith Evans and Nominal Defendant Notorious B.I.G., LLC.

McCORMICK, C. 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.”1 After Wallace’s

tragic death, however, his mother and widow did exactly the opposite—forming

Notorious B.I.G., LLC (the “Company”) under Delaware law to manage the late

rapper’s intellectual property. This litigation was perhaps the inevitable result.

Wallace’s mother passed away in 2025. In her will, she left her interest in the

Company to a trust, which the Company’s LLC Agreement identified as a transferee

“permitted” to receive membership units. Originally, Wallace’s mother had named

her grandson as a successor trustee. Just weeks before she died, however, she

amended the trust agreement to remove her grandson and name the plaintiff as the

sole trustee. The plaintiff then attempted to effectuate the trust agreement by

asserting the trust’s rights to membership units in the Company. 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 plaintiff filed this action, seeking in part a declaration that the trust is a

member of the Company. The plaintiff has moved for partial summary judgment on

that claim. This decision grants the plaintiff’s motion for summary judgment and

dismisses the defendant’s mirror-image counterclaim.

1 The Notorious B.I.G., Ten Crack Commandments, on Life After Death (Bad Boy

Records 1997). I. FACTUAL BACKGROUND

Drawn from the pleadings and exhibits submitted by the parties, the following

facts are undisputed.2

Notorious B.I.G., LLC is a Delaware LLC formed in 2007 by Voletta Wallace

and Faith Evans. Voletta and Evans are the mother and widow, respectively, of the

late rapper Christopher Wallace, also known as “The Notorious B.I.G.”3 They formed

the Company to manage the intellectual property created and owned by Christopher

Wallace.4

On March 8, 2023, Voletta and Evans signed an Amended and Restated

Operating Agreement of Notorious B.I.G., LLC (the “LLC Agreement”).5 The LLC

Agreement contains a Delaware choice-of-law provision.6 The LLC Agreement

designated Voletta and Evans as Managers of the Company.7

Voletta and Evans each owned 50% of the membership “Units” and were the

sole Members of the Company.8 Through the LLC Agreement, Voletta and Evans

2 This decision cites to exhibits to transmittal affidavits and declarations accompanying the parties’ briefing on the plaintiff’s motion for summary judgment by the docket entry and “Ex.” letter. At times, this decision refers to individuals by their first names to distinguish them. The court intends no familiarity or disrespect. 3 C.A. No. 2025-0760-KSJM, Docket (“Dkt.”) 78, Decl. of Faith Evans (“Evans Decl.”),

Ex. AA (“Pennsylvania Petition”) ¶¶ 7, 8. 4 Dkt. 71, Decl. of Wayne Barrow (“Barrow Decl.”), Ex. E (“LLC Agreement”) § 3.1(c).

5 Id.

6 Id. § 13.10.

7 Id. §§ 1.1 (defining “Member”), 6.1(a).

8 Id., Schedule A; see also, id. § 1.1 (defining “Units”)

2 each assigned half of their interests in distributions to Christopher Wallace’s

children, Ty’anna Wallace and Christopher Jordan Wallace (“CJ”).9 As a result,

Voletta, Ty’anna, CJ, and Evans were each entitled to 25% of the Company’s

distributions.

The LLC Agreement includes provisions that govern the admission of new

members.10 It states that, “[s]ubject to the terms and conditions of this Agreement,

at any time and from time to time, any Person acceptable to the Members, by

unanimous vote, may become a Member of the Company for such consideration, and

upon such other terms and conditions, as the Members shall unanimously agree.”11

The LLC Agreement also governs the transfer of membership Units. It

provides that a Member may assign or transfer its membership Units, directly or

indirectly, to a “Permitted Transferee” “who executes an instrument in form and

substance reasonably satisfactory to the Manager, assuming the rights and

obligations of such Member under this [LLC] Agreement.”12

The LLC Agreement identifies the “Voletta Wallace Revocable Trust u/a/d

December 14, 2020” (the “Trust”) as one of two Permitted Transferees. 13 Voletta

created the Trust under an agreement dated December 14, 2020 (the “Trust

9 Id. § 4.10(b); Barrow Decl., Ex. F (“Will”) art. I.

10 LLC Agreement § 5.3.

11 Id.

12 Id. § 8.1. This decision quotes Sections 8.1 and 5.3 in full in the Legal Analysis. 13 Id. § 1.1 (defining “Permitted Transferee”).

3 Agreement”) and served as the Trust’s grantor and trustee. 14 As originally drafted,

the Trust Agreement named as successor trustees CJ, Voletta’s friend Carol

Sampson, and Plaintiff Wayne Barrow,15 and bequeathed Voletta’s interest in the

Company to the Voletta Wallace Foundation.16

Also on December 14, 2020, Voletta executed a Last Will and Testament (the

“Will”). The Will left Voletta’s estate to the Trust on her death.17 The Will named

CJ, Sampson, and Plaintiff as executors.18

On February 6, 2025, Voletta amended the Trust Agreement (the “Trust

Amendment”).19 The Trust Amendment removed CJ and Sampson as successor

trustees, leaving Plaintiff as the sole trustee. The Amendment also removed the

provision specifically bequeathing Voletta’s interest in the Company to the Voletta

Wallace Foundation and directed the Trustee to distribute any assets not specifically

bequeathed to the Christopher Wallace Memorial Foundation.20 On the same day,

Voletta executed a codicil to the Will (the “Codicil”) that removed CJ and Sampson as

executors, leaving Plaintiff as the sole executor of Voletta’s estate.21

14 Barrow Decl., Ex. H (Trust Agreement) at 1.

15 Id. art. XVII.

16 Id. art. VI.

17 Will art. III.

18 Id. art. V.

19 Barrow Decl., Ex. I (“Trust Amendment”).

20 Id. §§ 6, 12, 13; Trust Agreement at art. VII.

21 Barrow Decl., Ex. G.

4 Voletta passed away on February 21, 2025.22 On March 6, Plaintiff accepted

his appointment as a successor trustee of the Trust.23 On April 21, the Register of

Wills of the Commonwealth of Pennsylvania, County of Monroe, issued Letters

Testamentary in Voletta’s estate to Plaintiff as executor of the estate.24

On Voletta’s death, Evans became the sole Manager of the Company and

stopped making distributions to the Trust.25 Plaintiff requested distributions by an

Free access — add to your briefcase to read the full text and ask questions with AI

Wayne Barrow, as Trustee of the Voletta Wallace Revocable Trust v. Faith Evans, (Del. Ct. App. 2026).

Wayne Barrow, as Trustee of the Voletta Wallace Revocable Trust v. Faith Evans (Wayne Barrow, as Trustee of the Voletta Wallace Revocable Trust v. Faith Evans) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Telxon Corporation v. Meyerson
802 A.2d 257 (Supreme Court of Delaware, 2002)
Rhone-Poulenc Basic Chemicals Co. v. American Motorists Insurance Co.
616 A.2d 1192 (Supreme Court of Delaware, 1992)
Pellaton v. Bank of New York
592 A.2d 473 (Supreme Court of Delaware, 1991)
DCV Holdings, Inc. v. ConAgra, Inc.
889 A.2d 954 (Supreme Court of Delaware, 2005)
Achaian, Inc. v. Leemon Family LLC
25 A.3d 800 (Court of Chancery of Delaware, 2011)
XO Communications, LLC v. Level 3 Communications, Inc.
948 A.2d 1111 (Court of Chancery of Delaware, 2007)
Randy v. Progressive Northern Insurance Co.
785 A.2d 281 (Supreme Court of Delaware, 2001)
Continental Oil Company v. Pauley Petroleum, Inc.
251 A.2d 824 (Supreme Court of Delaware, 1969)
Allen v. Encore Energy Partners, L.P.
72 A.3d 93 (Supreme Court of Delaware, 2013)