But Smith's daughter Dannielynn Birkhead may be eligible for the estate of E. Pierce Marshall, the son of Smith's ex-husband, thanks to a new ruling this week.
Marshall's estate was ordered to pay sanctions over "massive discovery abuse" in the Koch Industries heir's legal battle against his stepmother, the late Smith.
The judge said that Marshall's estate allegedly used "delaying tactics" to keep legal documents from Smith, including mailing them to a lawyer in Lake Charles, La.
The Marshall estate is estimated at between $500 million and $1 billion. J. Howard Marshall died in 1995 at age 90 after being married to Smith, then 26, just one year. Smith was not included in his will.
Smith died after an overdose in 2007. The judge ruled that 6-year-old Dannielynn Birkhead is entitled to sanctions against the Marshall family and could receive up to $49 million.
"This is a complete vindication of Anna Nicole's rights and a total condemnation of what was done to her, lawyer Phil Boesch told Forbes.