Brandon Ross was convicted of burglary, aggravated assault, and firearm offenses after a home invasion in which masked men shot a victim. During deliberations, the jury asked to review Ross’s video-recorded police statement and watched it in the jury room under the supervision of a bailiff. Ross argued that replaying the recording outside open court violated the continuing-witness rule and unfairly emphasized the statement, which was the strongest evidence connecting him to the shooting. The Georgia Court of Appeals held that the procedure was improper and that the error was not harmless. The jury could stop and start the recording in the jury room, and the other evidence was not overwhelming because no victim identified Ross and the verdict followed shortly after the replay. The court reversed the judgment. A special concurrence agreed and urged trial courts to limit any replay of audio or video evidence to open court rather than sending recordings into the jury room during deliberations.