Ministry of Social Development lawyer Richard Williams told the court that Roberts appeared in court yesterday "in relation to the death of his partner's son".
Judge Couch recalled the case, saying: "I saw him yesterday."
Mr Williams said the ministry wanted to proceed with the prosecution, saying it will "go on a separate path, of course".
Judge Couch remanded Roberts at large to appear in court on June 18.
Leon was laid to rest at a "remembrance and farewell for our special wee dude" at Avonhead Baptist Church in Christchurch yesterday.
A death notice paid tribute to "our little superman was tragically taken from us, surrounded by his loving family and trusty sidekicks".
"Treasured, adored and greatly loved son of Emma and James, chief mischief maker of his brothers and sisters Lucas, Nadia, Anabelle, Fabian, and Liam; Giane, Daniel, and James," it said.
https://givealittle.co.nz/cause/riplittleleon# set up last week to help the family with the funeral expenses has so far raised more than $4400.