Attorneys appeared Monday with Brice Brian McMillan, 41, and his wife Sandra Elizabeth McMillan, 36, of Macclesfield.
"It's a sad case," defense attorney Allen Powell, who represents Brice McMillan, said after the hearing. He declined any further comment, and the couple did not enter a plea.
Tyler Gene McMillan was buried Monday morning next to his mother in Greenville. An obituary in the Greenville Daily Reflector said the boy was raised in Pitt County and enjoyed reading, fishing, karate, being a Boy Scout and watching professional wrestling.
The county sheriff's office has said Brice McMillan told a deputy the teen was being disobedient and was forced to sleep outside last Tuesday while tied to a tree. The teen was released Wednesday morning, but again tied up that night for bad behavior.
Sheriff James Knight has said the boy was left tied to the tree until the following afternoon, when his stepmother found him unresponsive. Authorities believe the boy was bound to the tree with plastic ties and possibly other kinds of material.
Arrest warrants for both McMillans said the child sustained "bruising to the wrist, cuts to entire body, missing flesh from buttocks, results from being tied to a tree for approximately 18 hours resulting in death."
The warrants didn't reveal a specific cause of death. An autopsy is pending at the state's chief medical examiner's office in Chapel Hill.
Two other children living in the McMillans' home, ages 7 and 9, have been placed in the custody of the Department of Social Services, authorities said. The teenager's obituary said he has a brother and stepsister.
Macclesfield is about 60 miles east of Raleigh.