MSUKeith,
I'm sure Cory will respond too, but the answer to your question is yes, 1020 has difficulty achieving any type of reasonable hardness (> 35 HRC) unless it is water quenched in thin sections (only several mm thick). For pliers, the surface transforms quickly, but the center, even if it is only 2 or 3 mm below the surface, will be 50% martensite or less, meaning lots of ferrite, pearlite, maybe some bainite.