George Nicolau, a prominent arbitrator who determined that Major League Baseball teams colluded in the 1980s to restrict bidding for free agents, leading club owners to pay players $280 million in damages, died on Jan. 2 in Manhattan. He was 94.

His stepson John Oppenheimer said the cause was kidney failure.

Mr. Nicolau was named baseball’s independent arbitrator in 1986, replacing Thomas T. Roberts, whom owners had fired as he was hearing the first collusion case between them and the Major League Baseball Players Association.

After the owners were ordered to reinstate Mr. Roberts so that he could finish hearing the case — which the news media came to call Collusion I — he ruled that owners had conspired to curtail the free market for players’ services after the 1985 season.

Then it was Mr. Nicolau’s turn to enter that caldron of tension. A longtime fan of the Detroit Tigers, he brought an extensive background as a labor lawyer and an arbitrator for the National Basketball Association and its union as well as in other fields, like aviation, communications and entertainment.