Mayra Lizbeth Rosales, 27, who weighs nearly 450 kg (1,000 pounds), has been charged with striking her nephew Eliseo at least two times on March 18, crushing the child's head.
A grand jury on Thursday indicted Rosales, from La Jola, Texas, on one count of first-degree murder and on one count of injury to a child.
However, the woman never appeared in court because of her weight and was released without bail, based on her promise to return to court as required. As of Thursday evening, she was not in custody.
The Monitor online edition cited a local sheriff, Lupe Trevino, who said detaining her for a court trial would be impossible.
"She would die," he said, because she needs full medical care. He added that the suspect would still soon face arrest, without revealing the details of the process.