A dispute between Washington Redskins defensive end Dexter Manley and his former attorney James Kiles over legal fees must be resolved in arbitration before the National Football League Players Association rather than in a court of law, a Fairfax Circuit Court judge ruled yesterday.

Judge Lewis H. Griffith ruled that one portion of a suit Kiles filed against Manley in November 1983, claiming $18,080 in attorney's fees, was a question only the NFLPA had the right to resolve.

NFLPA regulations established in 1983 mandate that disputes between players and their agents, who must be certified by the association, can only be resolved by arbitration and have no place in the courts, said Richard Berthelsen, general counsel for the 1,600-member association.

This is the first time a judge has cited these regulations as reason a case involving players and their agents should not be heard, said Berthelsen. He and Manley's attorney, Wallace Christensen, hailed yesterday's order as a sign that the NFLPA regulations are recognized and respected by the courts.

"I think the significance of the ruling is that it ensures players' rights under collective bargaining agreements will be enforced and protected by the courts," Christensen said.

"It is an affirmation that the (NFLPA) regulation system is appropriate and legal," said Berthelsen.

In addition to legal fees Kiles alleged he was owed, he was suing Manley for $500,000 for libel and slander, claiming Manley defamed him in remarks published in several newspapers in July 1983. That part of the suit is to be heard in Fairfax County Circuit Court Feb. 12.

William Schewe Jr., attorney for Kiles, said yesterday he had not decided whether to appeal the order. "I'm not happy about it," he said. "I think the judge misconstrued the NFL document he looked at. But there's no bitterness."

In July 1983, Manley, who was then entering the final year of a three-year contract, retained Richard Bennett, also a Washington-based attorney, to represent him in contract negotiations.

The new NFLPA regulations were part of an effort to gain a larger role in how players' wages were negotiated, Berthelsen said. To be certified the agent must agree to abide by NFLPA rules, including arbitration of disputes between players and their attorneys.