Technology-assisted review (TAR) refers to iterative active learning workflows for document review in high recall retrieval (HRR) tasks. TAR research and most commercial TAR software have applied linear models such as logistic regression or support vector machines to lexical features. Transformer-based models with supervised tuning have been found to improve effectiveness on many text classification tasks, suggesting their use in TAR. We indeed find that the pre-trained BERT model reduces review volume by 30% in TAR workflows simulated on the RCV1-v2 newswire collection. In contrast, we find that linear models outperform BERT for simulated legal discovery topics on the Jeb Bush e-mail collection. This suggests the match between transformer pre-training corpora and the task domain is more important than generally appreciated. Additionally, we show that just-right language model fine-tuning on the task collection before starting active learning is critical. Both too little or too much fine-tuning results in performance worse than that of linear models, even for RCV1-v2.