I think of it more as an issue of quality control. I haven't abused similar enough 1095 knives to speak from personal experience with regards to rust resistance and strength in general but, I have with ATS-34.
A knife made exactly the same (blade thickness, length, grind, etc.) heat treated to the same RC number can exhibit better or worse performance due to the grain structure present after the heat treat. I have had mass produced ATS-34 folders from two manufacturers that were victims of a correct RC value (as best I can tell) but, poor quality control heat treats. In one case, I had a Benchmade that rusted (stained significantly but, no pits) in my pocket after a day of heavy sweating. The neck knife I carried the same day did not stain. This knife had a brittle edge as well so, I assume it was heat treated too quickly resulting in a large grain structure that allowed more microscopic space for sweat the cling to even though it was a polished blade. The relative brittleness of the blade re-enforced this belief in a bad heat treat. In the second knife, again a mass produced ATS-34 blade, the blade shows minor chips during sharpening that cannot be sharpened out due to the fact that removing one releases another in the cutting edge somewhere else. Again, I suspect a bad heat treat.
I have several custom ATS-34 blades that show none of these weaknesses. I also have several other production ATS-34 knives that don't show these defects, including other knives from the same manufacturer.
I attribute most of these differences not to the actual RC value but, the underlying grain structure created during the heat treat. If you control grain growth during the heat treat, you will get a knife that, at the same RC value, will be much tighter which helps inhibit staining. I attribute this to a "smoother" surface at the microscopic level that holds less sweat, salt, etc. The smaller grain structure is more forgiving of force whether lateral along the knife or a hard impact into the cutting edge.
The TOPS and Newt Livesay knives I have used are different enough that I am not comfortable doing a direct comparison of them other then to say both have a great heat treat. It was Newt Livesay's knife that gave me a new found respect for 1095. The knife is extremely comfortable to use, holds an edge extremely well, is easy to touch up after a lot of use with ordinary sharpening tools and, forgiving of impacts with hard things (rocks, nails, etc.). The TOPS knife has these same attributes but, its thicker profile from the spine to cutting edge, give it a totally different application and feel.
The Quality Control during Heat Treat is the key. How many people have complained about CPM steels in production knives but, love them in customs? How much of this is attributable to the Heat Treat quality control? Comparing knives that do not have the same edge geometery's and blade profiles would not be a fair comparison of relative strengths but, if one has a good heat treat and the other does not, you will notice the difference if you use them hard whther 1095 or ATS-34.