Yup, it's the impact toughness of 1095 that makes it preferred over D2. The high level of carbides in D2 means it has high wear resistance, which means the edge will dull less when cutting soft materials. It's also why D2 is such a b*tch to sharpen.
This gives awesome EDC performance, but at the cost of low impact toughness, which means there is a lower propensity of the steel to bend instead of chip under high impact energy. For a small, EDC blade this is less imporant, but high IT is usually wanted in any hard cutting knife- and obviously especially for choppers. However, many of Cliff Stamps reviews noted poor performance of 1095 steels with regards to low impact toughness and brittle fracture- apparently due to poor HT QC.