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The Notorious B.I.G. was a key player in bringing sampling to the forefront in hip-hop in the 1990s. On songs like “Juicy” and “Big Poppa,” Biggie and his production team reworked beloved older songs into new beats for him to rap over. One such song, “Ten Crack Commandments” from his sophomore album Life After Death, led to some hurdles behind the scenes.

The Notorious B.I.G., who sampled Chuck D in his song 'Ten Crack Commandments', performing on stage
The Notorious B.I.G. | Chris Walter/WireImage

Inside the recording of The Notorious B.I.G.’s ‘Ten Crack Commandments’

Biggie’s producer DJ Premier reflected on the creation of “Ten Crack Commandments” in a 2003 interview with XXL. Biggie wanted to incorporate a sample from Public Enemy’s 1991 song “Shut ‘Em Down” into the song — in particular, a scratch and snippet of Chuck D’s voice.

“To make a long story short: on ‘Ten Crack Commandments’ Big went in there and did the vocals and the only thing that Big instructed me to do besides what was already laid down was, ‘Every time I say number one, number two, number three, take that Chuck D scratch and scratch it with me saying the number.’ I said, ‘No problem,'” Premier remembered. “I did that, it came out to be another hit.”

Biggie himself was proud of how the song turned out. “I think it’s one of the best records he ever made,” Premier said. “As soon as he was done with the vocals he goes, ‘Premier, I did it. I did it. I’m the greatest!’ And that was the last time I ever saw him.”

Chuck D wasn’t happy with the song’s title

Public Enemy co-founder Chuck D wasn’t too pleased with “Shut ‘Em Down” being used for a song where Biggie outlines rules for drug dealers. Biggie never lived to see the song released, as he died in March 1997, just two weeks before his Life After Death album was released. Still, Chuck D brought a copyright lawsuit against Biggie’s estate (as well as DJ Premier) regarding the song.

“It was the fact that it was called ‘Ten Crack Commandments.’ Chuck’s not into that. He doesn’t want his voice affiliated with anything that involves drug use or drinking alcohol, sex, or whatever,” Premier said. “So they came after me and Biggie’s estate, saying that basically we violated in the fact that we used him in a song that condoned drug use. I didn’t look at it that way, because, to me, that record was to cats in the street. So, to wrap that up, I told him — this is after the fact that Big had passed already, and [his death] was still fresh — I told Chuck, ’cause I was on tour with him, I was like, ‘Yo Chuck, why don’t you be easy on that? Because I feel like, why should we have to go through this when Big is dead and he’s not here to defend this lawsuit. You gonna put his mother through it? I don’t think that’s spiritually fair.’ He said, ‘You know what? If it gets out of hand with everything, I’ll dead it.’ I said, ‘OK, fine.’ He never deaded it.”

Premier wasn’t pleased with how Chuck D was proceeding with the lawsuit.

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DJ Premier was upset with Chuck D for years

Chuck D didn’t back down from the lawsuit, leaving a bad taste in DJ Premier’s mouth. When Premier ran into Chuck D on the street, he didn’t mince words.

“I found Chuck one day around my neighborhood that I live in now. He happened to tap me on my shoulder, he was with his kids and I got into it with him a little bit,” Premier recalled. “I never spoke to him again and I started kind of having a little hate for him to a certain degree. I felt like he was a hypocrite. I would never sue a dead man, especially Big. I thought that was spiritually wrong, especially for what he stands for. Because I love Chuck D as a lyricist, a performer and a writer and as the head of Public Enemy. I love what he represents, and I felt like that was a foul on the fact that he couldn’t let a man’s death override a lawsuit. I’d rather it be all on my back than have to go sue a dead man’s estate. It put a big dent in the rap game.”

Chuck D settled the lawsuit against Biggie’s estate in November 1998, according to MTV News. A few years later, Premier and Chuck D buried the hatchet. “I saw Chuck at Jam Master Jay’s wake [in 2002], and we spoke and we got everything behind us now,” Premier said.

“Ten Crack Commandments” wasn’t the only Life After Death song to face obstacles because of samples: “I Got a Story to Tell” led to Biggie’s producer’s imitating a sample rather than ripping it entirely to skirt around clearance issues.